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Tax Court Rejects Offer in Compromise on Wesley Snipes' $23.5 Million Debt

Chris Gaetano
Published Date:
Nov 6, 2018

A tax court rejected Hollywood actor Wesley Snipes' offer in compromise on $23.5 million in delinquent tax debt, where he offered to pay $842,061, roughly 4 percent of the outstanding balance, according to Accounting Today. Sniped served three years in prison for failing to file a tax return between 2001-2006. After his release in 2013, the IRS assessed his liabilities and sent a notice demanding payment. Snipes refused to pay. The IRS then issued a federal tax lien against him, at which point he requested an offer in compromise. That was when he offered the IRS the $842,061 in cash, which the IRS rejected, leading Snipes to file suit in tax court to get the agency to accept the offer, leading to the court to ultimately side with the IRS. 

Snipes has been identified as part of the Sovereign Citizen movement, which, among many other things, holds that only activities explicitly named in IRS Code Section 861's section 1.861-8T(d)(2)(iii) can be taxed. The case Gould v. Gould, though, concluded that this is an incorrect interpretation, saying that "In the interpretation of statutes levying taxes it is the established rule not to extend their provisions, by implication, beyond the clear import of the language used, or to enlarge their operations so as to embrace matters not specifically pointed out. In case of doubt they are construed most strongly against the government, and in favor of the citizen." This was the argument that Snipes tried to employ to defend not filing taxes, leading to his eventual incarceration. 

Other arguments that members of this movement have tried, and failed, to employ in tax court include: as a sovereign individual they are not subject to federal tax laws; that the federal jurisdiction only extends to the District of Columbia and federal land; that a taxpayer is not legally a person and therefore not subject to tax law; that only federal employees are subject to federal taxes; and that the gold fringe around U.S. flags in court rooms implies that only maritime law is applicable there. 

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