The Thirteenth Amendment provides that "[n]either slavery nor involuntary servitude ....shall exist in the United States ...." Although the Supreme Court has upheld the constitutionality of income tax withholding, in the context of the corporate income tax, as early as 1916,83 a few taxpayers have still contended, unsuccessfully, that to require an employer, without compensation, to withhold income taxes from the wages of employees places the employer in involuntary servitude in violation of the Thirteenth Amendment.84 The courts have consistently and repeatedly held that a requirement of governmental service of this character does not constitute involuntary servitude. A government has the right to require certain actions of its citizens, including income tax withholding, jury service, and military service.85

83 Brushaber v. Union Pacific Railroad Co., 240 U.S.1(1916).

84 See, for example, Lorre, Jr. v. United States, 40 A.F.T.R. 2d 5664 (W.D. Tex. 1977); and United States v. Awerkamp, 34 AF.T.R. 2d 5086 (7th Cir.1974).

85 See, Arver v. United States, 245 U.S. 366 (1918); Butler v. Perry, 240 U.S. 328 (1916); and Robertson v. Baldwin,165 US. 275 (1897).