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Cindy's Post Hoc Document filed
May 1st 2003
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Cynthia L. Neun, in proper person
444  East Sahara Avenue
Las Vegas, Nevada 89104
PHONE:    702-385-6920
FAX:        702-385-6917


UNITED STATES                                                 CASE NO:  CV - S-03-0281-LDG-RJJ       
Plaintiff                                                  POST HOC BRIEF
LAWRENCE N. COHEN, a/k/a/)          :
LARRY COHEN, individually and              
All doing business as FREEDOM    

Defendant named in the above- entitled action, Cynthia L. Neun, respectfully submits this as her sworn testimony, and asks this Court and the Government Attorneys to consider it to be in substantial conformity with the proper form for what the Court requested, "post hoc brief", and that for the sake of convenience and respect for all the Parties time, allow this Defendant to incorporate all of the pleadings in the brief filed by the ACLU, and, by her co-Defendant, Mr. Schiff, for Defendant is in complete agreement with the statements of fact and issues of law made by Mr. Schiff on the Record thus far and adopts them as her own..
Defendant raises a question of this Court's jurisdiction now that she has taken time to research the jurisdictional requirements of the Code Sections involved that the Government brings, and, attached in Defendants Points and Authorities. Defendant has a serious concern now, based upon what she has learned about this Court's jurisdiction over her.  But, Defendant is afraid to lose her rights, so, she will continue to appear on that condition.  This "brief" is due, and, Defendant must file it even though she believes this Court lacking in jurisdiction, as will be explained.

The Government comes to this Court with Code sections 6700, 6701, 7408, and 7402 as the basis for their Complaint and the Court's jurisdiction to bring on an Injunction and to ban a book, and to deprive Defendants of all kinds of Constitutional Rights and protections secured to them by both the State of Nevada and the United States, in order to protect the Government's revenue and scarce Treasury Department employee resources; to unclog the Courts; and, to "Shut the Scam down!"  The Government must impose the penalties before they come to this Court, and, jurisdiction of the Court does not come in to play until the Government imposes the penalty, (not both, but only one, 6700 OR 6701), as explained later, and, then, if Defendants further engage in the activity, see: Joint Committee on Taxation Report, (EXHIBIT A-5), to prevent the Defendants from further engaging in such activities, the Court shall claim jurisdiction over the matter, "provided that the government has satisfied the statutory requirements.".
Whenever a penalty is imposed under chapter 68, certain procedural requirements must be met before the penalty may be assessed, as outlined in Subchapter C.
"IR Code Section 6751. Procedural requirements.
(a)Computation of penalty.
The secretary shall include with each notice of penalty under this title information with respect to the name of the penalty, the section of this title under which the penalty is imposed, and, a computation of the penalty."

Further, whenever a penalty is imposed, the law and the agency's own regulations provide for Administrative hearings processes and Appeals.  The person is entitled and required to exhaust administrative remedies before proceeding to a Court of law seeking remedy.  The same is true for the Government. Even if the penalties were applicable to Irwin Schiff's teachings and his Book, The Federal Mafia, and even if the Government had actually notified the Defendants that they were subject to the penalties, which, they are not, the Government must follow its own regulations or everything they do from there on is null and void.  See  Regulation 601.106 (f).

IR CODE SECTIONS 6700, 6701, 7408 AND 7402:

1. NO NOTICE OF DETERMINATION AND NO PENALTIES IMPOSED.  This Court must find good cause shown for the fact that Government's Record in this case is want of constructive Notice to the Defendants that their speech, teachings, books and research material put them in violation of Internal Revenue Laws 6700 and 6701 and 7408, before they came to this Court.  The Internal Revenue Service and The Department of Justice employees have failed to mention to Defendants that they are in violation of any Internal Revenue Law, when both Departments have had countless numbers of opportunities to do so as the record in this case will prove.
Defendants have never been notified that a penalty has been determined, or imposed against them, or anything like that.  Defendants never received any bills, statements, notices or demands for any payment to be made to the Internal Revenue Service for being found subject to,
or for being found in violation of provisions  6700 and 6701 of Internal Revenue Code . The Government never sent a fraud investigator to visit Freedom Books to speak with the Defendants regarding any infractions of IR Code Section 7408, 7602, or any other laws they may have violated.  The Government has not attempted to revoke the Defendant's CAF Numbers, recognizing Defendants as Taxpayer representatives for other individuals. The Government did not do any of these things that the law, the regulations, the Administrative Procedures Act, the Internal Revenue Manual, the Special Agents Handbook, and a host of other legal reference guides state that they are required to do before they can come inconveniencing this Court and injuring the Defendants.
For over a decade, (since Mr. Schiff's first zero return filings), this continued to go on, with the Government receiving thousands upon thousands of new "zero 1040 return" filings each year.  The Government did not notify Defendants, (nor any of their customers), in any way that promoting and selling the book, THE FEDERAL MAFIA: HOW THE GOVERNMENT ILLEGALLY IMPOSES AND UNLAWFULLY COLLECTS INCOME TAXES, or, any of Mr. Schiff's extensive supporting research and applications found in his "Seminars", "Audio Reports: Series 1 through 7", "Audit Packet",  "Lien and Levy Packet", "Due Process Role-Play Seminar", "Tax Court Tool Kit", or any other materials sold at Freedom Books made Defendants subject to the provisions of Code Sections 6700 and 6701 or 7408 until the Government came to the Courts. This Defendant put this on the Court's record on April 11, 2003, (Transcript Page 148), and, the Court asked no questions of the Government's Attorney about this inexcusable problem with the Government's case, nor did the Government Attorney attempt to object or to explain its reason for this neglect. 
This neglect is fatal error.

The transcript of the Preliminary Injunction Hearing on April 11, 2003, shows, (page 4), the Court indicates what the Court "thinks this case is all about", stating:
"There are a number of sections of the law that apply.  Perhaps one of the most important is Section 7408 of Title 26 and its entitled "An Action to Enjoin New Promoters of Abusive Tax Shelters" and it reads as follows. It gives authority for the government to seek an injunction."

Section 7408 Action to enjoin promoters of abusive tax shelters, etc.
(a)Authority to seek injunction.
A civil action in the name of the United States to enjoin any person from further engaging in conduct subject to penalty under section 6700 (relating to penalty for promoting abusive tax shelters, etc.) or section 6701 (relating to penalties for aiding and abetting understatement of tax liability) may be commenced at the request of the Secretary. Any action under this section shall be brought in the district court of the United States for the district in which such person resides, has his place of business, or has engaged in conduct subject to penalty under 6700 or section 6701.  [The court may exercise its jurisdiction over such action (as provided in section 7402 (a)) separate and apart from any other action brought by the United States against such person.] 
(b)Adjudication and decree.
In any action under subsection (a), if the court finds 
(1)that the person has engaged in any conduct subject to penalty under section 6700 (relating to penalty for promoting abusive tax shelters, etc.) .) or section 6701 (relating to penalties for aiding and abetting understatement of tax liability), and
(2)that injunctive relief is appropriate to prevent recurrence of such conduct,

the court may enjoin such person from engaging in such conduct or in any other activity subject to penalty under section 6700 or section 6701.

The transcript reveals that the Judge briefs the parties on what the case is about for more than eight pages talking about various court decisions that are relevant in his mind, and that reduce Mr. Schiff's and other named Defendant's First Amendment rights to a non-issue, and other matters decided by the courts, such as burden of proof, but those requirements do not have to be reached when it is commercial speech, and, [page 9 Line 17], Brandenburg v. Ohio, the Supreme Court ruled that abstract advocacy of lawlessness is protected speech["And the case goes on to suggest"], the Court says,
"It rarely has been suggested that the constitutional freedom for speech and press extends its immunity to speech or writing used as an integral part of conduct in violation of a valid criminal statute and we reject the contention now."

And, then the Court says, [pages 11 and 12], that the government believes that Mr. Schiff's book would be publishable if Mr. Schiff took "Chapter 8 out" and "the epilogue and the examples of telling people how to do things". "And, of course those returns, in many cases, contain the names of people."  The point is, the Court and the Government stayed far away from 6700 and 6701, the reading and consideration of which would ruin the Government's case, and, they did not even open the book, The Federal Mafia to refute one statement contained therein.
Internal Revenue Code section 6700, entitled "Promoting abusive tax shelters" cannot apply to Defendants and their bookstore.
The Joint Committee on Taxation in 1999: Defines "Tax Shelter": (Exhibit A-8.); "Promoting Abusive Tax Shelters, (Section 6700)", and Aiding and Abetting Understatement Of Tax Liability, (Section 6701) are both defined and discussed in Defendant's (Exhibit A-4). Also, the Court should note that the Statute, 6701(3), Coordination with 6700, states that:
"No penalty shall be assessed under section 6700 on any person with respect to any document for which a penalty is assessed on such person under subsection (a). (of this section, 6701)

The Joint Committee on Taxation agrees, as shown on Defendant's Exhibit A-4:

"Coordination rules apply such that a person who is subject to the aiding and abetting penalty is not also subject to the return preparer penalty (sec.6694) or the promoter penalty (sec. 6700)."

There must be an imposition of the penalty against the person involved in a plan or arrangement that makes, or causes another person to make statements to the allowability of any deductions or a gross valuation overstatement in order to claim credits or other benefit by holding an interest in the entity, or, participating in the plan or arrangement, which the person knows or has reason to know is false or fraudulent" It requires that there be an organization, entity or plan.  As Mr. Schiff has already adequately pleaded, Defendants are not involved in any of that.  The Defendants could not know that they were doing anything "false or fraudulent" even if they were involved in an organization, entity or plan, which they are not, as the Defendants case clearly shows, because the Government failed to send them constructive notice of the penalty they are allegedly subject to.  The imposition of the penalties involved is the statutory requirement of the Government, and, then, the Defendants would have had to have notice of this, and they would have had to continue to be in violation of the sections of law after the imposition and notice, before the Court can claim jurisdiction on the Government's Complaint against Defendants. That's the legislative intent behind the laws as shown in the law itself and in Defendant's EXHIBIT A-5.
The Government  nor the Courts - have ever called the zero 1040 return an "abusive tax shelter", and they have never used the terminology that the return was "false or fraudulent" until now, where the Government looks to this Court to make it so by Court Decision, ignoring the fact that this is not a criminal trial and that false and fraudulent return filings are criminal in nature.  The purpose of Code Sections 6700 and 6701 are to "encourage voluntary compliance, according to the Internal Revenue Manual, (EXHIBIT B), and the fact that no "liability" for the income tax is found in the Internal Revenue Code, (EXHIBIT C), and no provision for the "payment" of the income tax in the Internal Revenue Code, as evidenced by Defendant's (EXHIBIT D), further proves Defendant's defense for all of these "charges" brought by the Government.
After the Court's introduction of the case, the U.S. Attorney Evan Davis, was invited to take over the Government's case, who said that he thought the Government had made its case based upon the fact that Mr. Schiff's attorney did not attempt to articulate Mr. Schiff's argument, when indeed she would have certainly done so, if it were based upon law, but, "her failure stems from the fact that she risks being "sanctioned"-(by this very Court)-" for bringing up a frivolous argument", says Evan Davis, [Page 14, Line 17 to Page 15, Line 3.]   Then Mr. Davis said that he felt the case "should now focus on the appropriate scope of the preliminary injunction".
Here, Evan Davis, has disqualified Mr. Schiff's attorney, Noel Spaid, by stating that she does not dare bring up the fact that income tax is based on voluntary compliance and self-assessment, without risking Court sanctions, which undoubtedly the U.S. Attorney could use to prejudice another Court against her somewhere down the line. [Page 14, Line 16].
Then, on [Page 15, Line 19], Mr. Davis brings in IR Code Section 7206, a statute that Defendants could be in violation of if they are allowed to keep selling the book, and that the Court had already pointed out that the Defendant's could be enjoined from future violations of criminal statutesand then Mr. Davis explains that criminal prosecutions can take months if not years so the Court can enjoin the Defendants now, presumably to keep the Defendants from breaking the criminal statutes later on down the line; or, perhaps the Defendants are already guilty of the criminal statutes, (the Government does not say for sure), and the Court can protect the Government from having to meet its burden of proof on the criminal end, if the Court will help the Government "stop the harm now", justifying the Courts ruling with a phrase called "requisite intent" to file false documents. Perhaps the Government and Courts like to dispense justice this way so that people like the Defendants are not "clogging up" the Criminal Courts, too.  But, Defendants are not involved in a criminal trial. They have not been charged with any criminal offense.  Could the Courts be circumventing the necessity to convene trials in the Criminal Courts by "taking care of the matter in Civil Court, since everybody is already there on other civil statutes?" 

Defendants know that they are walking into a trap here with these Courts, but Defendants are thankful to be at this vantage point to see the bigger trap the Government has built for itself:
1.The Government claims that this is the "Biggest Tax Scam in U.S. History" and that it has been going on for 30 years, and under IRC 6700, 6701, 7408, and 7402, and, the Government is now coming in to "Shut the Scam down!" But, the Government Attorney has not stated for the Court's record, how it is that the Defendant's "Scam" went on for 30 years without the Government notifying the Defendant's that they could be made subject to the penalty; where the Government did not impose a penalty against Defendants; and, where the Government had countless numbers of opportunities to do so, before the Government made a complaint with the Court.
2.The Government claims that Defendants have been operating illegally as they have been conducting Seminars and Workshops all across the country:  (But, the Government never mentions it to Defendants.)  The Government did nothing to attempt to stop Defendants from advertising the Seminars or from hosting the Seminars, but come to this Court to Complain about all of these violations of the Internal Revenue laws for the very first time.
3.If Defendants are in violation of any Revenue Laws, then the Government is an "accessory" to these violations by issuing millions of letters to the Public filing the zero returns; sending out glossy tri-fold brochures and full refund checks, instead, and, never managing to mention to the Defendants and their customers that they were involved in filing "false" or "fraudulent" returns, or "abusive shelters".  Therefore, the Government led the Defendants and the rest of the Public on for over a decade at least, (and according to U.S. Attorney Davis on this case, over 30 years),


The Government has a problem: "Burden of Proof". The Government's problem is not with the Defendants in this case.  The Government's problem is with an Act of Congress enacted to reign in renegade IRS agents who were executing countless numbers of liens, levies and seizures every year in open violation of law. The 1998 Restructuring and Reform Act gives the American Public rights to administrative due process and a right to judicial review of the administrative due process if an adverse determination is made to seize property by distraint when the IRS has not met its burden of proof including the presentment of verification from the Secretary of the Treasury or his delegate that all of the administrative procedures and applicable laws have been met. Congress made the new laws very specific indeed.  They require that the Internal Revenue Service comply with the laws that were already in the Internal Revenue Code prior to the enactment of this very important Legislative Act of Congress.
They are great laws for the Public, unless they are not true.  If the American people have no rights when it comes to dealing with the Internal Revenue Service, then the law is the scam and the hoax, because the law says that they most certainly do. And, this is what is "clogging" the Courts: The fact that the Internal Revenue Service employees cannot get the documents that the law says they must have, which lead to illegal determinations to seize property anyway, and the fact that the American Public is waking up to the fact that they can rely on the laws passed by Congress to protect themselves from this kind of behavior unless the Courts will not apply these laws when they make their decisions.
What Defendants do is read the law out loud, word for word, and they go on to read the index of the Internal Revenue Code; the implementing Code of Federal Regulations; The Federal Register; Internal Revenue Manual; the job descriptions of IRS personnel; the Internal Revenue Bulletin; the Privacy Act Notice of the 1040 Booklet; the United States Attorneys Bulletins; Congressional and Senate Reports; and various Internal Revenue Service Publications to find what applicable law and administrative procedures are required to be met.
Defendants are acknowledging the fact that they have shown thousands of individuals what the Law says regarding their Appeal Rights and judicial review before the Government may seize property. The Government contends the Defendants committed crimes against their own friends, relatives and customers,  when Defendants showed others how to exercise these rights as enacted by Congress. 

The Government seeks relief from the Court for what it calls "The biggest Tax Scam in U.S. history", pleading that the Court enjoin Defendants in order to "Shut the scam down!"  The Government has come to this Court with  "unclean hands" and is otherwise committing fraud upon the Court.

The Government, having met face-to-face on a continuing basis (hundreds of times) with the Defendants and communicated via mail, (thousands of pieces of correspondences), facsimiles and telephone conversations with Defendants on a regular basis over the course of the past 4 to 5 years. Defendants have carried the Internal Revenue Code into every meeting they have attended and where they have challenged the Government employees to show Defendants any law requiring Defendants to pay income tax, making them liable for income tax, and/or, providing for penalties and interest in the event they do  not pay the income tax.
The Privacy Act Notice of the 1040 Instruction Booklet puts the Public on Notice of three IR Code sections that apply to the 1040 Form: 6001, 6011, and 6012.  Those three Code sections are dependent upon a "liability" for tax.  And, as Defendant's (EXHIBITS B and C) already prove, the liability exists when the Public makes itself liable by voluntarily filing a 1040 Form listing wages and other sources of income on the Form and by calculating an amount of tax due.
What Defendants have discovered and are able to prove to this Court at the time of trial is that Government employees know full well that they are the parties operating outside the bounds of the law when they attempt to assess or to collect the income tax.  Hundreds of transcripts and tapes and Affidavits will prove that even the agents working inside the agency know these facts to be true.  The transcripts of hearings where people have filed "traditional" Returns are most revealing.  The agents working on those cases actually admit on the record that the individual made him or herself liable when they filed the Form claiming their wages as income for income tax purposes. Defendants have heard the agents state these facts many times.
The Government has failed to give any Notice in this case that Defendants teachings, Representative activities, return filings, or citizen rights advocacy is in any way misleading, false, fraudulent or criminal, when Defendants have been personally appearing before the Internal Revenue Service and conducting this work in the presence of Revenue Agents, Appeals Officers, Managers and Team Leaders on a regular basis; Internal Revenue Service Chief Counsel and Department of Justice Attorneys on a more limited basis, over the course of the past four to five years.
This Defendant has appeared hundreds of times at the Internal Revenue Service, (probably more times than any other private citizen in America), representing individuals in Examinations Functions, Appeals Functions and before the Taxpayer Advocacy Program in Las Vegas, Nevada, and Defendant has received thousands of letters from various Internal Revenue Service personnel, including District Directors and other Senior Officials, acknowledging her position as Taxpayer Representative and un-enrolled return preparer for perhaps more than one hundred individuals since 1999.   Not one employee, agent, officer, attorney or official working for the Internal Revenue Service, the Department of Justice or the Department of Treasury has ever mentioned to Defendant that she is in violation of any Internal Revenue Law. 
When Defendant asks the Government's agents to point to a law that they are applying or enforcing; agents do not attempt to point to the law even when the Internal Revenue Code Book is on the table in front of them. And as the direct response instead, the Government's agents cite Tax Court Memos or District Court Decisions as their authority to do what they are doing. No Notice whatsoever given to Defendants, where opportunity clearly exists, proves therefore, the Government is not entitled to be entertained by the Court  much less entitled to look for relief from this Court.  Surprise and neglect constitute fraud and abuse - and voids all processes, actions, orders, and appeals.  Defendants are entitled to release from the Restraining Order, based upon the facts set forth above.


The Court should be able to clearly see already, Defendants here are not the Government's ordinary "pickings".  Of the many indictments the U.S. Attorneys are making against Defendants, is that they are "running the biggest Tax Scam in U.S. History!"  When, in FACT: The Government comes seeking protection from the Defendants because Defendants can prove conclusively through the Governments own documents, correspondences and transcripts of all kinds, that the Government is committing a colossal fraud on the American Public by manipulating and threatening lawmakers, policy writers, the nation's lawyers and CPA's, and they get away with it by abusing America's Courts.
The Government points to past decisions of Courts to justify a long list of its dirty deeds, and then when necessary, as it is with these Defendants, they come back to America's Court System, blackmailing the judiciary with the Court's own words, making the Court a guilty party in the action, when the Government knowingly won those Decisions by committing fraud upon the Courts. This blackmail and intimidation must stop, for it has corrupted America's Courts, and the Courts obviously cannot find a way to stop it when the evidence needed is scarce. Defendants in this case can stop it with overwhelming proof and evidence from all across America to expose the fraud, and the Defendants are eager, in fact, to produce it; and, the Courts are duty bound to hear it; and therefore, the Defendants offer a golden opportunity for the Courts: to stop the fraud, and to take back their Courts.
The Government is not entitled to the Court's protection; they are entitled to the Court's disdain and punishment for seeking to enjoin their victims, the Civil Courts, in a criminal "cover-up". Defendants pray that the Courts will not join in or to submit to more blackmail, but to exercise courage and integrity now where it counts to end what really is "The Biggest Tax Scam in The History of The World", the United States Government's Tax Scam!

The mere fact that this case and all of the other "civil" and alleged potential "criminal" cases against Defendants exist, in consideration of the facts already set forth above, is proof that the United States Attorneys are involved in a criminal conspiracy and they are attempting to hijack these Courts for their own protection.

Defendants are not attorneys. Defendants have no templates with standard defenses and footnotes like the Government has.  Defendants are working on their home computers not knowing when the next "SEALED SEARCH WARRANT" will pop up on their doorsteps and there will be swarms of "cops with guns" and  "high tech equipment" all around.  Defendants know that if the Government can delay or entrap Defendants with the Search Warrant/Seizure case, Injunction case, the gag order, and, the book banning, they will most certainly do it, for it is the Government's only chance, save one to get these three Defendants out of the way.
Defendants only call upon the Courts integrity, and inherent powers of discretion to make many past wrongs right based upon clear and conclusive newfound evidence. Defendant knows that the Court can do that.  That's what Courts are for.
The Government needs the full cooperation and compliance of the Courts to rule according to the Government's will:
The very survival of the Government's colossal conspiracy is being brought to the Courts for protection, for it will be fully exposed and documented like never before in this case brought against these three Defendants.
The only way the Government can win this case is to use procedural ploys and to intimidate the Courts. If the Courts will simply refuse to be blackmailed by the Government and allow the Defendants to make their cases, for which the Courts are duty-bound to do, the Government's whole scheme is doomed, and the American Public and their Courts will be set free from the Government's oppressive schemes.

Every one of these "Civil" Court Battles constitutes malicious prosecution, and the Government knows it, and that is why the Government needs to bring an avalanche of cases after disarming the Defendants.
None of these cases would have been initiated to begin with if the Government had any legal basis for its claim against Defendants. If the Government had a law making persons liable for or requiring them to pay income taxes, as it was written in the 1939 Code, (EXHIBIT E), they would not need to employ the Attorneys and the use of a judge, because Defendants are law-abiding citizens who have agreed to comply with the laws hundreds of times before the IRS, and many times before the DOJ, but all of these Government employees have refused to identify those laws. The transcripts seized by the Government reveal the astonishing confessions made by Government Attorneys and IRS employees.
Defendants are entitled to have trials and to make their case, and the Defendants have a right to hear the Government's case. The Public has a right to hear the Government's case in its entirety. If indeed Irwin Schiff and his cohorts run the biggest Tax Scam in America's History, let, the U.S. Attorney open the book: "THE FEDERAL MAFIA", to read one passage or to refute one statement made therein.  If the Courts are going to allow this kind of unruliness and brutality and public degradation to go on against the Defendants then the Court must prepare to allow it all in full view of the American people.  If this is the "big one", then let it be seen and let it be heard so that there is no room left for doubt by those who are watching. The Court must allow all parties to be heard.

The mere fact that this battery of "civil" cases are being brought on by the Government all at once serves as a "confession" that the Government cannot prosecute Defendants criminally. Even if the Government had a true cause of "civil" action against Mr. Schiff and his two co-Defendants, it "sat on those (so-called) 'rights'" for thirteen years, charging no person with any crime for filing the zero return and imposing no penalties against Defendants, which is required before it can bring the matter to this Court - Mr. Davis, United States Trial Attorney, attempts to "woo" this Court into changing even more laws outside the jurisdiction of this Court, to suit his "case" here and to set a very dangerous precedent in this Court which if not reversed, would eventually deny all kinds of citizens their right to challenge the validity of the Government's claims in these matters.

Defendants cannot comply with the Temporary Restraining Order as written without giving the Government what could be used as a confession that the lectures, and the book and materials they have been advertising and selling are "knowingly false and misleading and that fall under aiding and abetting persons to file a false return", and other charges along that line. Therefore, the very ORDER as issued by the Court, is a giant trap and cannot be complied with by Defendants.  

Further, if Defendants are not relieved of the Temporary Injunction, and must proceed to the Permanent Injunction,
A Jury Trial is Demanded.

Dated:  Thursday, May 1st, 2003
Respectfully submitted,

Cynthia L. Neun


This is to certify that a copy of the foregoing was faxed by Defendant to United States Trial Attorney, Evan Davis, at 202-514-6770.

Cynthia L. Neun

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