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States, and subject to the jurisdiction thereof, are citizens of the United States and of
the State wherein they reside.” The Fourteenth Amendment, therefore, establishes
simultaneous state and federal citizenship. See United States v. Cruikshank, 92 U.S.
542, 549 (1875) (“The same person may be at the same time a citizen of the United
States and a citizen of a State. . . .”); In re Slaughter-House Cases, 83 U.S. (16 Wall.)
36, 74 (1873) (A man “must reside within the State to make him a citizen of it, but it is
only necessary that he should be born or naturalized in the United States to be a citizen
of the Union”). The Fourteenth Amendment’s granting of citizenship applies to all
persons born or naturalized in the United States, regardless of race. See, e.g., Bell v.
State of Maryland, 378 U.S. 226, 249 (1964) (Douglas, J., concurring) (“The Fourteenth
Amendment also makes every person who is born here a citizen; and there is no
second or third or fourth class of citizenship.”).
Section 7701(a)(9) of the Internal Revenue Code states that “[t]he term 'United
States' when used in a geographical sense includes only the States and the District of
Columbia.” Claims that individuals are not citizens of the United States but are solely
citizens of a sovereign state and not subject to federal taxation have been uniformly
rejected by the courts. See, e.g., United States v. Hilgeford, 7 F.3d 1340, 1342 (7th Cir.
1993) (“The defendant in this case apparently holds a sincere belief that he is a citizen
of the mythical “Indiana State Republic” and for that reason is an alien beyond the
jurisdictional reach of federal courts. This belief is, of course, incorrect.”); United States
v. Gerads, 999 F.2d 1255, 1256 (8th Cir. 1993) (“[We] reject appellants’ contention that
they are not citizens of the United States, but rather “Free Citizens of the Republic of