How have the courts treated the issue of income tax in the context of federal reserve notes?

Kalms next argues that he was not required to pay income taxes because federal reserve notes are only worth five cents and therefore his total income was exempt from income tax. This court had rejected the same argument. See, e.g., Cook v. Spillman, 806 F.2d 948, 949 (9th Cir.1986).

Next he makes several arguments in connection with the court's instructions to the jury. First he says that the district court erred in repeatedly instructing the jury that it had to follow the law as given by the court. Second, he complains of the court's failure to give his proposed "good faith" instruction. Finally, he argues that the district court erred in instructing the jury that government misconduct was not a defense to his prosecution. This court reviews the district court's formulation of jury instructions for abuse of discretion. United States v. Hayes, 794 F.2d 1348, 1351 (9th Cir.1986).