Gerald J. and Gayle R. Martinez - Page 5

                                                  -5-                                                   
                        lar, the guarantee of the free exercise of reli-                                
                        gion.                                                                           
                              *     *     *     *      *     *     *                                    
                  10. The The [sic] contents of the Internal Revenue                                    
                        Service Code and the methods employed by the In-                                
                        ternal Revenue Service to force compliance with                                 
                        laws that violate the nature [sic] law and the                                  
                        conscience and religious convictions of a person                                
                        violate the Constitutions [sic] and laws of the                                 
                        United States, in particular the due process                                    
                        clause of the Fifth Amendment and the equal pro-                                
                        tection clause of the Fourteenth Amendment; and                                 
                        the RICO Statute.                                                               
            We reject the reasons advanced by petitioners in support of their                           
            position that they are not liable for tax for the years at issue.                           
            In Adams v. Commissioner, 110 T.C. 137, 139 (1998), this Court                              
            concluded that                                                                              
                  while petitioner's religious beliefs are substantially                                
                  burdened by payment of taxes * * *, the Supreme Court has                             
                  established that uniform, mandatory participation in the                              
                  Federal income tax system, irrespective of religious belief,                          
                  is a compelling governmental interest. * * * 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.  * * * [Cita-                          
                  tions omitted.]                                                                       
            See Hernandez v. Commissioner, 490 U.S. 680 (1989); United States                           
            v. Lee, 455 U.S. 252 (1982).                                                                
                  Petitioners further assert that they are not liable for tax                           
            for the years at issue because respondent's "cause of action was                            
            prescribed [sic]" when respondent mailed the notices on June 28,                            
            1995.  We disagree.  Section 6501(c)(3) provides that, in the                               
            case of failure to file a return, "the tax may be assessed, or a                            
            proceeding in court for the collection of such tax may be begun                             




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