## Facts

- Lawrence Stephen Maxwell and over 560 other plaintiffs sent substantially identical letters to the IRS seeking numerous categories of tax-related records for multiple years, including “return information,” records purportedly proving notice of a duty to file, and materials allegedly establishing federal “jurisdiction” to tax them.
- The requests also demanded identification of specific statutory provisions allegedly making each requester liable for federal taxes or requiring particular forms.
- The IRS treated the letters as requests under FOIA and the Privacy Act and informed requesters that FOIA requests must reasonably describe the records sought and comply with IRS FOIA regulations (including identification and fee-related requirements).
- Maxwell and others refused to treat the letters as FOIA requests, asserting that 26 U.S.C. § 6103 provided an independent mechanism to obtain “return information” without FOIA compliance.
- Plaintiffs filed suit seeking (i) compelled disclosure of requested records and (ii) broad declaratory and injunctive relief declaring they were not subject to federal income tax and restricting IRS authority.
- The district court dismissed the disclosure claims for FOIA noncompliance and lack of exhaustion, and dismissed the declaratory and injunctive claims as frivolous.

## Issues

1. Whether 26 U.S.C. § 6103 provides an independent basis to obtain IRS “return information” that allows requesters to bypass FOIA’s procedural requirements.
2. Whether the district court properly dismissed plaintiffs’ declaratory and injunctive claims challenging federal tax liability and IRS authority as frivolous.

## Decision

- The court of appeals affirmed.
- Section 6103 does not create a FOIA-free disclosure process; IRS record requests remain subject to FOIA’s procedural requirements, including regulations governing sufficiency of requests and administrative exhaustion.
- The IRS properly treated plaintiffs’ letters as defective FOIA requests, and dismissal of the disclosure claims was proper.
- The declaratory and injunctive claims were correctly dismissed as frivolous because they rested on meritless “tax protester” theories and sought relief generally barred or sharply limited in federal tax matters.

## Legal Principles

- FOIA provides the procedural framework for requesting records from federal agencies; requesters must submit a request that reasonably describes the records and comply with applicable agency FOIA regulations, including exhaustion requirements.
- Section 6103 is principally a confidentiality statute with limited disclosure provisions; it does not displace FOIA procedures for processing record requests.
- Prior precedent recognizing § 6103 as governing access to “return information” (as compared to the Privacy Act) does not authorize avoidance of FOIA’s procedural requirements.
- Claims asserting that ordinary citizens are not subject to federal income tax absent special jurisdictional proof, or that tax liability depends on individualized “jurisdiction” records, lack an arguable basis in law and may be dismissed as frivolous.
- Broad declaratory or injunctive relief interfering with federal tax assessment or collection is generally unavailable absent narrow statutory or doctrinal exceptions.

## Conclusion

The D.C. Circuit held that § 6103 does not provide an independent route to compel IRS disclosures without following FOIA procedures, and it affirmed dismissal of plaintiffs’ sweeping tax-liability challenges and requests to restrict IRS authority as frivolous.


Maxwell v. Snow, 409 F.3d 354 (D.C. Cir. 2005)