Everett Street v. Commissioner of Internal Revenue

Eleventh Circuit

Everett Street v. Commissioner of Internal Revenue

CourtCourt of Appeals for the Eleventh Circuit

DecidedJune 15, 2026

Docket25-14033

StatusUnpublished

This text of Everett Street v. Commissioner of Internal Revenue (Everett Street v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Everett Street v. Commissioner of Internal Revenue, (11th Cir. 2026).

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USCA11 Case: 25-14033 Document: 29-1 Date Filed: 06/15/2026 Page: 1 of 2

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-14033 Non-Argument Calendar ____________________

EVERETT VINCENT STREET, Petitioner-Appellant, versus

COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. ____________________ Petition for Review of a Decision of the U.S. Tax Court Agency No. 1295-25 ____________________

Before JORDAN, KIDD, and ED CARNES, Circuit Judges. PER CURIAM: Everett Street didn’t pay his 2018 income tax. After the In- ternal Revenue Service (IRS) sent him a notice of deficiency in his income tax for that year, proceeding pro se, he petitioned the USCA11 Case: 25-14033 Document: 29-1 Date Filed: 06/15/2026 Page: 2 of 2

2 Opinion of the Court 25-14033

United States Tax Court for review of that notice. In the petition, he argued that he “is not [a] person made liable” for the payment of taxes by the Internal Revenue Code (IRC) and the federal per- sonal income tax is an unconstitutional, non-apportioned direct tax. The Tax Court dismissed the petition for failure to state a claim for which relief can be granted and ordered Street to pay his $2,964 deficiency in federal income tax for 2018, as well as penalties for late filing and late payment. Street appealed, raising the same core arguments as he did before the Tax Court: 1) he is not subject to federal income tax be- cause he is “not a person made liable by statute for the payment of the indirect income tax” and 2) the federal income tax violates the Sixteenth Amendment as an unconstitutional, “non-apportioned direct tax.” But as the Tax Court concluded, all his arguments are frivolous. See Stubbs v. Comm’r, 797 F.2d 936, 938 (11th Cir. 1986) (explaining that the arguments that “wages are not taxable income and that [a citizen is] not a person required to file a tax return” “are patently frivolous”); Motes v. United States, 785 F.2d 928, 928 (11th Cir. 1986) (deeming frivolous the argument that income tax vio- lates the Sixteenth Amendment). AFFIRMED.1

1 Because Street’s remaining arguments stem from his frivolous ones, and all

share their frivolity, we decline to address them further. All pending motions are DENIED as moot.

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USCA11 Case: 25-14033 Document: 29-1 Date Filed: 06/15/2026 Page: 1 of 2

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-14033 Non-Argument Calendar ____________________

EVERETT VINCENT STREET, Petitioner-Appellant, versus

COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. ____________________ Petition for Review of a Decision of the U.S. Tax Court Agency No. 1295-25 ____________________

Before JORDAN, KIDD, and ED CARNES, Circuit Judges. PER CURIAM: Everett Street didn’t pay his 2018 income tax. After the In- ternal Revenue Service (IRS) sent him a notice of deficiency in his income tax for that year, proceeding pro se, he petitioned the USCA11 Case: 25-14033 Document: 29-1 Date Filed: 06/15/2026 Page: 2 of 2

2 Opinion of the Court 25-14033

United States Tax Court for review of that notice. In the petition, he argued that he “is not [a] person made liable” for the payment of taxes by the Internal Revenue Code (IRC) and the federal per- sonal income tax is an unconstitutional, non-apportioned direct tax. The Tax Court dismissed the petition for failure to state a claim for which relief can be granted and ordered Street to pay his $2,964 deficiency in federal income tax for 2018, as well as penalties for late filing and late payment. Street appealed, raising the same core arguments as he did before the Tax Court: 1) he is not subject to federal income tax be- cause he is “not a person made liable by statute for the payment of the indirect income tax” and 2) the federal income tax violates the Sixteenth Amendment as an unconstitutional, “non-apportioned direct tax.” But as the Tax Court concluded, all his arguments are frivolous. See Stubbs v. Comm’r, 797 F.2d 936, 938 (11th Cir. 1986) (explaining that the arguments that “wages are not taxable income and that [a citizen is] not a person required to file a tax return” “are patently frivolous”); Motes v. United States, 785 F.2d 928, 928 (11th Cir. 1986) (deeming frivolous the argument that income tax vio- lates the Sixteenth Amendment). AFFIRMED.1

1 Because Street’s remaining arguments stem from his frivolous ones, and all

share their frivolity, we decline to address them further. All pending motions are DENIED as moot.

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