Lazore v. Commissioner of Internal Revenue
United States Court of Appeals for the Third Circuit
11 F.3d 1180 (1993)
- Written by Matthew Celestin, JD
Facts
Glenny and Carol Lazore (plaintiffs) were members of the Mohawk Nation in New York, which was one of the six Indian tribes that composed the Haudenosaunee. Pursuant to the 1794 Treaty of Canandaigua (the treaty)—which stated, in part, that the Haudenosaunee were guaranteed the free use and enjoyment of their land—the Haudenosaunee largely operated as a separate nation with its own government. The treaty predated the federal income tax. Glenny worked as a mechanic for a metal company, and Carol worked for the Mohawk Nation. On their 1986 federal income-tax return, the Lazores reported the income from their jobs as nontaxable income. However, the Commissioner of Internal Revenue assessed a deficiency. The Lazores filed a petition in tax court, claiming that, as members of the Mohawk Nation, they were exempt from federal income tax pursuant to the treaty. After a trial in which the Lazores presented substantial historical evidence showing that the Haudenosaunee understood the treaty to grant the tribe status as a separate nation, the tax court held that the Lazores were not exempt from federal income tax. The Lazores appealed.
Rule of Law
Issue
Holding and Reasoning (Roth, J.)
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