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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
taxes).
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