UNITED STATES * 4:17-MC-1557 * Houston, Texas VS. * * 10:33 a.m. JOHN PARKS TROWBRIDGE * September 13, 2017

Transcription

1 0 0 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION UNITED STATES * :-MC- * Houston, Texas VS. * * 0: a.m. JOHN PARKS TROWBRIDGE * September, 0 APPEARANCES: MISCELLANEOUS HEARING BEFORE THE HONORABLE KEITH P. ELLISON UNITED STATES DISTRICT JUDGE FOR THE GOVERNMENT: Lewis Arnold Booth, II OFFFICE OF CHIEF COUNSEL 0 S. Gessner Rd., Suite 0 Houston, Texas 0..0 FOR DEFENDANT JOHN PARKS TROWBRIDGE: John Parks Trowbridge (Pro se) Memorial Blvd. Humble, Texas -0 Court Reporter: Johnny C. Sanchez, RPR, RMR, CRR Rusk, #00 Houston, Texas Proceedings recorded by mechanical stenography. Transcript produced by computer-assisted transcription.

2 0::0 0:: 0:: 0:: 0:: 0 0 THE COURT: Good morning and welcome. We'll turn to United States versus Trowbridge. We'll take appearances of counsel or parties. MR. BOOTH: Lewis Booth for the United States of America, Your Honor. THE COURT: Thank you. MR. TROWBRIDGE: By special appearance, John Parks Trowbridge, Jr. THE COURT: Okay. Thank you. It's the IRS's petition. Mr. Booth, anything you want to say? MR. BOOTH: Just generally, Your Honor. Respondent is making arguments that are not appropriate in this setting, or frankly any judicial setting concerning the applicability of the laws of Revenue Service to him. His allegation, if I understand it correctly, is that he is not a person subject to any of Internal Revenue laws, that the Internal Revenue laws only apply to federal government employees and citizens of the District of Columbia. These are argument that courts have consistently held to be frivolous. He has not alleged an abuse of process, and the IRS attempting to enforce the summons. He has not alleged that any of the Powell factors are defective in any way. The United States of America is entitled to have its summons enforced, and this

3 0:: 0:: 0:: 0:: 0:: 0 0 Court issue an order of compliance. MR. TROWBRIDGE: Judge, this is really not an opportunity to argue the merits of the case because Mr. Booth, who is a legal professional, has failed to respond to my motion to dismiss when notified of that failure, in the subsequent filing he's failed to respond or ask for an extension of time or offer a neglect or excuse, and he's failed to respond to the motion for summary judgment. I'm unclear, but I believe under the rules I'm entitled to summary judgment in that situation. THE COURT: Well, you moved for both a motion to dismiss and a motion for summary judgment. And I'm -- it doesn't compel the government to respond to either if it doesn't want to. The arguments you have been thought of by other people. I'm sure you understand that if the Internal Revenue Code only applied to residents of District of Columbia and America territories, other people would have chosen not to pay their taxes. And the arguments you're not a person, if I understand that correctly, that's clearly been tried before. I can't find any legal authority for any of the arguments you're advancing. MR. TROWBRIDGE: Well, Judge, as I

4 0:: 0::0 0:: 0:: 0:: 0 0 understand, statutes mean what they say. Under the definitions of terms of the statute are the ones that must be used, not just generally definitions or dictionary definitions. I'm more than willing to pay my taxes. My concern is I have well put in the merits of the case is that according to these definitions, I cannot find that I am under that qualification, that I am under that liability. And, again, I cannot see that this is where the merits of the case are to be discussed. We are dealing with my motion for summary judgment and my motion to dismiss, none of which Mr. Booth has given an adequate response. THE COURT: But we have, we set this hearing to discuss every pending motion. And what the IRS has asked for is a show of cause order, you filed the motion to dismiss and a motion for summary judgment. And as I stated, these arguments, because Texas is a sovereign and the federal government cannot exercise here, these have been advanced many times by other taxpayers, and those trying to avoid taxes. Do you have any law at all that suggests that there's judicial precedent in support of any of these arguments you're making? MR. TROWBRIDGE: Just that the law means

5 0::0 0:: 0:: 0:: 0:: 0 0 what it says. The statutes have termed those definitions do not apply in this case, as I've shown quite adequately in the filings. And, again -- THE COURT: But are there any cases that hold that? I'm a lowly district court. Can you give me any authority that suggests that you're correct in these arguments? MR. TROWBRIDGE: I understand the Supreme Court has said repeatedly the statutes mean what they say, and that definitions are to be drawn from the statutes with regard to the terms. And I have illustrated those. And, again, my concern is I have a motion for dismissal, I have a motion for summary judgment. And Mr. Booth has not responded to any of those in terms of presenting evidence in contradistinction to what I've offered. THE COURT: He has no obligation to respond if he doesn't wish to. And whatever the Supreme Court has said, if there's any basis for believing that the laws of the IRS do not apply to you, you haven't given me that authority. MR. TROWBRIDGE: Well -- THE COURT: The fact that they say that statutes mean what they are intended to mean, I understand that, but that doesn't really advance your argument at all. I don't know why that rule of construction comes to

6 0:: 0:: 0::0 0:: 0::0 0 0 your assistance in this context. MR. TROWBRIDGE: Judge, as I understand, Mr. Booth is operating on the presumption that I would be under the laws that he's seeking to enforce. THE COURT: And he's right about that. He's quite right about that. MR. TROWBRIDGE: But once a rebuttable presumption is challenged, Mr. Booth has an obligation, does he not, to present any evidence? THE COURT: No. There's no rebuttable presumption in interpretations of statutes, sir. I'm sorry. There's not. And he has no obligation to respond that argument if he doesn't want to. The Court can decide a motion to dismiss and motion for summary judgment without opposing papers. MR. TROWBRIDGE: Well, Judge, has Mr. Booth submitted any evidence with regard to me being a person or me being a citizen as those terms are used in the code he's seeking to enforce? MR. BOOTH: Your Honor, the government has filed the declaration of Revenue Agent Kendria Bruno, which goes through the four Powell factors as set forth in United States versus Powell, to allow the government to seek enforcement of the summons. Her declaration also indicates that there's no Justice Department referral.

7 0:: 0:: 0:: 0:0: 0:0: 0 0 Therefore, the summons that the government issued to respondent should be enforced by this Court. In addition, the government did file a response to petitioner's motion. Petitioner may not have been served with it. It could have been a clerical error in our office. We can provide him with a copy of that, but his motions, frankly, Judge, are frivolous. MR. TROWBRIDGE: Well, Judge, I understand that Mr. Booth has offered a declaration, and still that is not evidence as presented to the Court. A commentary by an agent does not constitute evidence, does it? MR. BOOTH: Your Honor, the cases made clear that a declaration of a revenue agent is prima facie evidence that this Powell factors have been complied with, and that the summons is enforceable. The obligation is then upon respondent to either allege an abuse of process, some sort of constitutional defense, or allege that one of the Powell factors is not relevant in this case or have not been followed. He has done none of those things. THE COURT: Mr. Trowbridge, do you contend that you alone, among those who live in Texas, are free from obligation to pay taxes, or do you think all Texans have that same right? MR. TROWBRIDGE: Judge, I have not addressed that question at all.

8 0:0: 0:0: 0:0: 0::0 0:: 0 0 THE COURT: That's why I'm asking you. I'm asking. MR. TROWBRIDGE: I simply looked at that with regard to myself and with regard to my specific circumstances. As Mr. Booth knows, prima facie evidence is nothing but rebuttable evidence. And if -- THE COURT: You haven't come forward with any rebuttal evidence. MR. TROWBRIDGE: I'm sorry, sir? THE COURT: You have not come forward with any rebuttal evidence. MR. TROWBRIDGE: He stated that the declaration of the agent was prima facie evidence. Am I misunderstanding what he's saying? THE COURT: No. I'm asking, you have not come forward with any rebuttable evidence to show you're not a person. MR. TROWBRIDGE: I understand in a civil case, Mr. Booth is supposed to establish the grounds of jurisdiction. And certainly whether I am a person or a citizen with regard to these laws would appear to be fundamental to establishing the jurisdiction. He's asking to exercise a territorial jurisdiction of a sum and subject matter, and has not offered what I understand to be evidence to the Court that

9 0:: 0:: 0::0 0:: 0:: 0 0 he's satisfied the jurisdiction of prerequisite. Everything else, then, of the merits is irrelevant. THE COURT: He's come forward with a declaration, there's ample precedent for the proposition that those who reside in the United States are subject to the income, Internal Revenue laws of the federal government. There's no requirement that the IRS prove you're a person. I'm sorry. There's just no requirement. And I don't understand where your argument comes from that you are not a person. MR. TROWBRIDGE: Judge, you're specifically stating there's evidence that I reside in the United States. That, of course, is a term, and a term that if you go through the motions that I have previously filed, suggest that that is the District of Columbia and not the United States of America, of which Texas is one of the freely associated compact states. THE COURT: So you're saying all Texans are spared any obligation to pay taxes to the federal government? MR. TROWBRIDGE: I'm not going to answer to all Texans. I'm certainly going to answer to me. And I've addressed those merits well in my filings in this case. THE COURT: Tell me what judicial authority

10 0 0:: 0::0 0:: 0:: 0::0 0 0 you can point me to that you're not a person, that you're not obligated to pay taxes, that Texas is not a state, that Texas is not subject to the Internal Revenue laws of the federal government. Give me any authority. MR. TROWBRIDGE: Well, Judge, I'm not sure that I actually stated Texas is not a state. And I'm not sure I stated that I am otherwise a different kind of party than just being me, a man, one of the people, entitled to fair application of the laws. And my understanding is that when Congress, the legislature states this is what the terms will mean, this is what they mean, and I have gone extensively through the merits of what the term means in the filings. And Mr. Booth has not shown anything, other than saying: Everybody knows that's hogwash. Everybody knows that the courts have ignored that before and everybody knows Powell. But Powell does not apply unless he gets jurisdictional prerequisite. And I cannot find in a case, unless I am mistaken, Judge, that he hasn't met his jurisdictional prerequisite to even have me here. MR. BOOTH: Your Honor, the Internal Revenue Code is clear. Code section , 0, 0, 0 allow the district courts to hear enforcement matters for IRS summons. The statutes are clear. MR. TROWBRIDGE: Well, Judge, I certainly

11 0:: 0:: 0:: 0::0 0::0 0 0 have no argument with that. And to those people to whom those statutes sections apply, then certainly the Court is going to work with the IRS in the enforcement question. However, if you were to bring someone from France -- and that's a classic argument -- or someone from South America in here and they have nothing to do with those statutes and the Internal Revenue Service, the Judge would certainly say: You haven't met a jurisdictional prerequisite. Well, in that case, I'm saying that if you look at how they define -- and Mr. Booth has read the law, and he understands what I've stated in my filings -- that the definitional statutes to which he's referring, I have clearly shown create a different kind of, quote, person, not someone like me. THE COURT: Give me one judicial precedent that is supportive of your argument. MR. TROWBRIDGE: Well, Your Honor, that would require me to go to the merits of the case and not to the motion to dismiss. THE COURT: No. It goes directly to jurisdiction. You said you want to talk about jurisdiction. MR. TROWBRIDGE: I'm sorry, sir? THE COURT: It goes directly to jurisdiction. You said you want to talk about

12 0::0 0:: 0:: 0:: 0:: 0 0 jurisdiction. MR. TROWBRIDGE: As I understand, I'm not the one to prove that I am, quote, the person that's a citizen. Mr. Booth is required to put evidence in the case. THE COURT: He's put evidence before the Court that shows that. MR. TROWBRIDGE: I'm sorry. What was that evidence, sir? THE COURT: He has come forward with a declaration, which is sufficient to show that. MR. TROWBRIDGE: I understood that I had an opportunity to submit actual rebuttable evidence. THE COURT: I'm asking for what your evidence is, either judicial precedent, or facts that have been presented by way of affidavit. MR. TROWBRIDGE: I believe I have presented in my filings adequate information in that regard, and I would be more than happy to respond to the Judge and present something more in detail to that particular question. I quite honestly did not expect that was a question in the Judge's mind about the declaration being a basically nonrebuttable item. THE COURT: I'm giving you every possible chance to rebut it. You just haven't done so.

13 0:: 0:: 0:: 0::0 0:: 0 0 MR. TROWBRIDGE: I understand that, sir, but I'm not that good on my feet as a legal professional because I'm not one, and did not come prepared to provide you. And I would certainly -- and this is no disrespect to you, Judge -- I would be more than happy to prepare the exact response that I could come up with in regard to that jurisdictional question. I apologize. I thought I'd answered that adequately in my filings, and I did not mean to mislead you in any way. MR. BOOTH: Your Honor, the United States of America believes that we are entitled to finality, at least at the District Court. We have an order compelling compliance a proposed order that this Court could sign. Mr. Trowbridge has made his arguments for the record, and if he likes, he has the ability to appeal to the Fifth Circuit if he thinks that your order is incorrect that you would enter on behalf of the United States. But to go back and forth, given the types of arguments that Mr. Trowbridge is making, is inappropriate, from the perspective of the United States of America. THE COURT: Do you have a proposed order? MR. BOOTH: Yes, Your Honor. May I approach. THE COURT: Yes. Have you shown it to

14 0:: 0:: 0:: 0:: 0:: 0 0 Mr. Trowbridge? MR. BOOTH: I will show it to Mr. Trowbridge, Your Honor. The United States of America requests at this time that Mr. Trowbridge appear before Kendria Bruno the September th at 0:00 o'clock. THE COURT: What time are you suggesting? MR. BOOTH: September th at 0:00 o'clock a.m. MR. TROWBRIDGE: Judge, if I might? THE COURT: Yes, sir. MR. TROWBRIDGE: I am preparing that day to leave for a week of educational materials and such, in California, and the following week would work. Anytime after that would work. MR. BOOTH: May I have just a moment, Your Honor? THE COURT: Yes, sir. MR. TROWBRIDGE: Judge -- THE COURT: Yes. Wait for Mr. Booth. Just a second. MR. TROWBRIDGE: Thank you. MR. BOOTH: That's October nd, Ms. Bruno is free. THE COURT: October nd work for you?

15 0:: 0:: 0:0:0 0:0:0 0:0:0 0 0 MR. TROWBRIDGE: Yes. THE COURT: 0:00 a.m.? MR. BOOTH: Yes, Your Honor. THE COURT: Okay. Order has been entered. MR. TROWBRIDGE: Judge -- THE COURT: Yes. MR. TROWBRIDGE: May I ask for a clarification, please? THE COURT: Yes. MR. TROWBRIDGE: So you are formally denying the motion for dismissal? THE COURT: Motion to dismiss and motion for summary judgment are denied, yes. MR. TROWBRIDGE: Judge, may I ask for a findings of facts and conclusions of law? THE COURT: There's no requirement of findings of facts or conclusions of law on motion for summary judgment. Motion to dismiss you failed to suggest any defect in the IRS's process, on motion for summary judgment you failed to show an absence of material fact about your relationship and your obligation to the IRS. MR. TROWBRIDGE: Judge, may I ask the opportunity to provide a specific filing to address that question, since I did not realize that that question was not, in your mind, addressed? I'm not a lawyer. I'm just

16 0:0: 0:: 0:: 0:: 0:: 0 0 trying to get through this. MR. BOOTH: Your Honor, Mr. Trowbridge has made adequate representations for the record to preserve his right on appeal to make these arguments if he sees fit. THE COURT: This isn't our first trip here, either. The other filing was in the end dismissed at the IRS request, but I don't think there's any lack of fair warning as to the government's position or any deficiency in what the government has done, in terms of providing you due process. So if you want to file a motion under Rule or Rule 0, you're welcome to. The Federal Rules do contemplate that. MR. TROWBRIDGE: I'm sorry, Judge. -- THE COURT: Rule or Rule 0 of Federal Rules of Civil Procedure, if you would like to file under either of those, you're entitled to whatever the law provides. MR. TROWBRIDGE: Would that be a motion for reconsideration? THE COURT: Well, there's no such thing as a motion for reconsideration in the federal system, but it's similar, similar thereto. Thank you very much.

17 (Recessed at 0: a.m.) COURT REPORTER'S CERTIFICATE 0 0 I, Johnny C. Sanchez, certify that the foregoing is a correct transcript from the record of proceedings in the above-entitled matter. /s/ Johnny C. Sanchez, CRR, RMR

18 /s [] - : 0 [] - 0: 0 [] - 0: 0 [] - 0: / 0 0:00 [] - :, :, : 0: [] - : th [] - :, : nd [] - :, : [] - :, :, : 0 [] - :, : 0 [] - 0: 0 [] - 0: A a.m [] - :, :, : ability [] - : above-entitled [] - : absence [] - :0 abuse [] - : according [] - : actual [] - : addition [] - : address [] - : addressed [] - :, :, : adequate [] - :, :, : adequately [] - :, : advance [] - : advanced [] - :0 affidavit [] - : agent [] - :, :, : Agent [] - : allege [] - :, : allow [] - :, 0: alone [] - : America [] - :, :, :, :, : ample [] - : answer [] - :, : answered [] - : anytime [] - : apologize [] - : appeal [] - :, : appear [] - :, : application [] - 0: apply [] - :, :, 0:, : approach [] - : argument [] - :, :, :, :, :, : arguments [] - :, :, :, :, :0, : assistance [] - : associated [] - : authority [] - :, :0, :, 0: avoid [] - : B basis [] - : behalf [] - : believes [] - : Booth [] - :, :, :, :, :, :, :, :, 0:, :, :, :0 BOOTH [] - :0, :, 0:, :, :, :, :, :, :, :, : bring [] - : Bruno [] - :, :, : C California [] - : cannot [] - :, :, :, 0: case [0] - :, :0, :, :, :, :, 0:, :, :, : cases [] - :, : certainly [] - :0, :, 0:, :, :, : CERTIFICATE [] - : certify [] - : challenged [] - : chance [] - : Circuit [] - : circumstances [] - : citizen [] - :, :, : civil [] - : Civil [] - : clarification [] - : classic [] - : clear [] - :, 0:, 0: clearly [] - : clerical [] - : Code [] - 0: code [] - : Columbia [] - : commentary [] - :0 compact [] - : compelling [] - : compliance [] - : complied [] - : concern [] - :, : conclusions [] - :, : Congress [] - 0:0 constitute [] - : constitutional [] - : construction [] - : contemplate [] - : contend [] - :0 context [] - : contradistinction [] - : copy [] - : correct [] - :, : course [] - : COURT [] - :, :, :, :, :, :0, :0, :, :, :0, :, :, :, :, :, :0, :, :, :0, :, :, :, :, :, :, :, :0, :, :, :, :, :, :, :, :, :, :, : court [] - : Court [0] - :, :, :, :, :0, :, :, :, :, : courts [] - 0:, 0: create [] - : CRR [] - : D dealing [] - : decide [] - : declaration [] - :, :, :, :, :, :, :, : defect [] - : defense [] - : deficiency [] - : define [] - :0 definitional [] - : definitions [] - :, :, :, :, :, :0 denied [] - : denying [] - :0 Department [] - : detail [] - :0 dictionary [] - : different [] - 0:, : directly [] - :0, : discuss [] - : discussed [] - :0 dismiss [] - :, :, :, :, :, : dismissal [] - :, : dismissed [] - : disrespect [] - : District [] - :, : district [] - :, 0: done [] - :, :, :0 drawn [] - :0 due [] - :

19 E G kind [] - 0:, : knows [] - :, 0:, 0:, 0: educational [] - : either [] - :, :, :, : end [] - : enforce [] - :, : enforceable [] - : enforced [] - : enforcement [] - :, 0:, : enter [] - : entered [] - : entitled [] - 0:, :, :, : error [] - : establish [] - : establishing [] - : evidence [] - :, :, :, :0, :, :, :, :, :, :, :, :, :, :, :, :, :, :, : exact [] - : exercise [] - :, : expect [] - : extensively [] - 0: F facie [] - :, :, : fact [] - :, :0 factors [] - :, :, : facts [] - :, :, : failed [] - :, :0 fair [] - 0:, : Federal [] - :, : federal [] - :, :, :, 0:, : feet [] - : Fifth [] - : file [] - :, :, : filed [] - :, :, : filing [] - :, : filings [] - :, :, 0:, :, :, : finality [] - : findings [] - :, : first [] - : fit [] - : followed [] - : following [] - : foregoing [] - : formally [] - :0 forth [] - :, : forward [] - :, :0, :, :, :0 four [] - : France [] - : frankly [] - : free [] - :, : freely [] - : frivolous [] - : fundamental [] - : generally [] - : given [] - :, :, : government [] - :, :0, :, :, :, :, :0, 0:, :0 government's [] - : grounds [] - : H happy [] - :, : hear [] - 0: hearing [] - : hogwash [] - 0: hold [] - : honestly [] - : Honor [0] - :0, :, 0:, :, :, :, :, :, :, : ignored [] - 0: illustrated [] - : inappropriate [] - :0 income [] - : incorrect [] - : indicates [] - : information [] - : intended [] - : Internal [] - :, 0:, 0:, : interpretations [] - : irrelevant [] - : IRS [] - :, :, :, 0:, :, :, : IRS's [] - : issued [] - : item [] - : Johnny [] - :, : Judge [] - :, :, :, :, 0:, 0:, 0:, :, :, :, :0, :, :, : judge [] - :, :, :, : Judge's [] - : judgment [] - :, :, :, :, :, :, :0 judicial [] - :, :, :, : jurisdiction [] - :0, :, :, :, :, :, :, : jurisdictional [] - 0:, 0:, :, : Justice [] - : I J K Kendria [] - :, : L lack [] - : law [] - :, :, :, :, :, : laws [] - :, :, :, :, 0:, 0: lawyer [] - : least [] - : leave [] - : legal [] - : legislature [] - 0:0 liability [] - : live [] - : look [] - :0 looked [] - : lowly [] - : M man [] - 0: material [] - :0 materials [] - : matter [] - :, : matters [] - 0: mean [] - :, :, :, 0:, 0:, : means [] - :, 0: merits [] - :, :0, :, :, 0:, : met [] - 0:, : might [] - :0 mind [] - :, : mislead [] - :0 mistaken [] - 0: misunderstanding [] - : moment [] - : motion [0] - :, :, :, :, :, :, :, :, :, :, :, :, :, :, :, :, :0, : motions [] - :, : MR [] - :, :, :, :, :, :, :0, :, :, :, :, :, :, :, :, :, 0:, 0:, 0:, :, :, :, :, :, :, :, :, :, :, :, :0, :, :, :, :, :, :, :, :, :, :0, :, :, :, :, :0 must [] - : N none [] - :, : nonrebuttable [] - : nothing [] - :, :

20 0 O o'clock [] - :, : obligated [] - 0: obligation [] - :, :, :, :, :, :, : October [] - :, : offered [] - :, :, : office [] - : once [] - : one [] - :, :, 0:, :, :, : ones [] - : operating [] - : opportunity [] - :, : opposing [] - : order [] - :, :, :, :, :, : otherwise [] - 0: P papers [] - : particular [] - :0 party [] - 0: pay [] - :, :, :, 0: pending [] - : people [] - 0:, : person [] - :, :, :0, :, :0, 0:, :, : perspective [] - : petitioner [] - : petitioner's [] - : point [] - 0: position [] - : possible [] - : Powell [] - :, :, :, :, 0: precedent [] - :, :, :, : prepare [] - : prepared [] - : preparing [] - : prerequisite [] - :, 0:, 0:, : present [] - :, :0 presented [] - :0, :, : presenting [] - : preserve [] - : presumption [] - :, :, : previously [] - : prima [] - :, :, : Procedure [] - : proceedings [] - : process [] - :, :, : professional [] - : proposed [] - :, : proposition [] - : prove [] - :, : provide [] - :, :, : provides [] - : providing [] - :0 put [] - :, :, : Q qualification [] - : quite [] - :, :, : quote [] - :, : R read [] - : realize [] - : really [] - : rebut [] - : rebuttable [] - :, :0, :, :, : rebuttal [] - :, : Recessed [] - : reconsideration [] - :, : record [] - :, :, : referral [] - : referring [] - : regard [] - :, :, :, :, :, : relationship [] - : relevant [] - : repeatedly [] - : REPORTER'S [] - : representations [] - : request [] - : requests [] - : require [] - : required [] - : requirement [] - :, :, : reside [] - :, : respond [] - :, :, : responded [] - : respondent [] - :, : response [] - :, :, : Revenue [] - :, :, 0:, 0:, : revenue [] - : RMR [] - : rule [] - : Rule [] - :, : Rules [] - :, : S Sanchez [] - :, : satisfied [] - : second [] - : section [] - 0: sections [] - : see [] - : seek [] - : seeking [] - :, : sees [] - : September [] - :, : served [] - : Service [] - : set [] - :, : show [] - :, :, :, :, :0 shown [] - :, 0:, :, : shows [] - : sign [] - : similar [] - : simply [] - : someone [] - :, :, : sorry [] - :, :, :, :, :, : sort [] - : South [] - : sovereign [] - : spared [] - : specific [] - :, : specifically [] - : state [] - 0:, 0: States [] - :, :, :, :, :, :, :, : states [] - :, 0: stating [] - : statute [] - : statutes [0] - :, :, :, :0, :, :, 0:, :, :, : still [] - : subject [] - :, :, 0: submit [] - : submitted [] - : sufficient [] - : suggest [] - :, : suggesting [] - : suggests [] - :, : sum [] - : summary [] - :, :, :, :, :, :, : summons [] - :, :, :, 0: support [] - : supportive [] - : supposed [] - : Supreme [] - :, : system [] - : T taxes [] - :, :, :, :, 0: taxpayers [] - :0 term [] - :, 0: termed [] - : terms [] - :, :, :, :, 0:, :0 territorial [] - : Texans [] - :, :, : Texas [] - :, :, :, 0:, 0:, 0: THE [] - :, :, :, :, :, :0, :0, :, :, :0, :, :, :, :, :, :0, :, :, :0, :, :, :, :, :, :, :, :0, :, :, :,

21 :, :, :, :, :, :, : therefore [] - : thereto [] - : thinks [] - : transcript [] - : trip [] - : TROWBRIDGE [] - :, :, :, :, :, :, :, :, :, :, :, :, :, :, 0:, 0:, :, :, :, :, :, :, :, :0, :, :, :, :, :, :, :0, :, :, :, :0 Trowbridge [] - :0, :, :0, :, :, :, : trying [] - :, : types [] - : U under [] - :, :, :, :, : understood [] - : United [] - :, :, :, :, :, :, :, : unless [] - 0:, 0: up [] - : V versus [] - : W wait [] - :0 warning [] - : week [] - :, : welcome [] - : willing [] - : wish [] - :