Priscilla M. Lippincott Adams - Page 5

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                  payments were spent in a manner that violates their                                    
                  religious belief.  Because the broad public interest in                                
                  maintaining a sound tax system is of such high order,                                  
                  religious belief in conflict with the payment of taxes                                 
                  affords no basis for resisting the tax.  [Id. at 260;                                  
                  citations omitted; emphasis added.]                                                    
            Thus, while petitioner's religious beliefs are substantially                                 
            burdened by payment of taxes that fund military expenditures, the                            
            Supreme Court has established that uniform, mandatory                                        
            participation in the Federal income tax system, irrespective of                              
            religious belief, is a compelling governmental interest.  See                                
            id.; Hernandez v. Commissioner, supra.  As a result, requiring                               
            petitioner's participation in the Federal income tax system is                               
            the only, and thus the least restrictive, means of furthering the                            
            Government's interest.  Cf. Steckler v. United States, No. Civ.                              
            A. 96-1054, 1998 WL 28235 (E.D. La., Jan. 26, 1998) (relying on                              
            United States v. Lee to hold that withholding pursuant to section                            
            3406 was the least restrictive means of furthering the compelling                            
            governmental interest of ensuring that all citizens participate                              
            in the tax system).  Therefore, we hold that RFRA does not exempt                            
            petitioner from Federal income taxes.  Accordingly, we sustain                               
            respondent's determinations.  Cf. Babcock v. Commissioner, T.C.                              
            Memo. 1986-168 (upholding additions to tax for failure to file                               
            and failure to make estimated tax payments where a Quaker                                    
            taxpayer claimed a religious exemption from Federal income                                   

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