The movement claim that statutes addressed to 'persons' bind only those who hold the corresponding legal status — leaving 'free men and women' outside the statute's reach — is foreclosed
The movement proposition
A recurring claim in the Byron Beers treatise corpus — and in the broader common-law / sovereign-citizen literature that draws on similar definitional sources — runs as follows. The legal term “person” is a fiction — a status that civil law creates, that the sovereign confers, and that can be revoked. The term “man” (or “natural man,” or “free man and woman”) refers to the human being in his or her natural condition outside the civil-law fiction. Statutes addressed to “persons,” “residents,” “individuals,” or similar status terms bind only those who hold the corresponding legal status. A natural man who declines to occupy the “person” classification — and who maintains his or her status as a natural man — is outside the reach of the statute.
The operative move is consistent across applications: the IRC’s income tax addressed to “every individual” or “every person” does not bind a natural man; the criminal statutes’ addressees are similarly status-bearing; the civil-procedure rules’ “persons” are similarly the legal-fiction sense.
The Beers version of the argument adds a historical dimension that the broader movement literature sometimes elides: older legal dictionaries (Bouvier’s 1856 and 1859 editions) did treat “person” as a status term encompassing corporations, the King, ministers exercising office, and slaves. The taxonomy is real legal history. Beers extends the historical fact to a contemporary statutory-construction claim.
The authority
Every modern American statute that uses the word “person” defines the term for its own purposes. The Internal Revenue Code provides the canonical example.
26 U.S.C. § 7701(a)(1) — “The term ‘person’ shall be construed to mean and include an individual, a trust, estate, partnership, association, company or corporation.”
The statute’s text expressly includes “an individual” as one of the entities “person” means within the IRC. The construction rule at 26 U.S.C. § 7701(c) confirms that “includes” in IRC definitions is non-exclusive: “The terms ‘includes’ and ‘including’ when used in a definition contained in this title shall not be deemed to exclude other things otherwise within the meaning of the term defined.” The IRC’s “person” definition is therefore at minimum the listed categories, and at maximum any other entity reasonably falling within the term’s ordinary meaning.
For the U.S. Code generally, the Dictionary Act at 1 U.S.C. § 1 establishes the default reading of “person”:
“In determining the meaning of any Act of Congress, unless the context indicates otherwise— … the words ‘person’ and ‘whoever’ include corporations, companies, associations, firms, partnerships, societies, and joint stock companies, as well as individuals;”
Same structure: “person” is expanded to include corporate and entity categories alongside individuals.
How “individual” is given operative meaning
Both statutes turn on the word “individual” alongside the corporate and entity categories. The IRC does not separately define “individual” — § 7701 lists many defined terms, but “individual” is not among them. Nor does the Dictionary Act define it. The operative meaning of “individual” in federal statutes that use the term is supplied by three converging sources:
The plain-meaning canon. When Congress uses a term and does not define it, courts apply its ordinary meaning unless context indicates otherwise. Wisconsin Central Ltd. v. United States, 138 S. Ct. 2067, 2070 (2018): “When called on to resolve a dispute over a statute’s meaning, this Court normally seeks to afford the law’s terms their ordinary meaning at the time Congress adopted them.” See also Taniguchi v. Kan Pacific Saipan, Ltd., 566 U.S. 560, 566 (2012) (statutory terms generally bear their “ordinary, contemporary, common meaning” absent specialized statutory definition). The ordinary meaning of “individual” in English is a single human being.
Treasury regulatory usage. 26 CFR § 1.1-1(a)(1) — the regulation operationalizing the income tax — applies the tax to “every individual who is a citizen or resident of the United States.” The regulation uses “individual” in the natural-person sense and has done so since the modern income-tax regulatory regime was set up. The same usage runs through the supporting regulations on residency (26 CFR § 301.7701(b)-1 et seq.) and on tax administration generally.
Federal case law. Federal courts that have heard the natural-man / declination argument in its various forms have uniformly construed “individual” in the IRC as a natural human being. The cases discussed in “Counter-authority” below — Sloan, Mundt, Slater, and the broader rejected-frivolous line — all rest on this construction. No federal court has accepted the contrary reading.
These three sources are the operative content of “individual” within the statutory floor that § 7701(a)(1) and § 1 establish. A litigant cannot escape statutory obligation by asserting their declination of the “person” status, because (a) the statute defines “person” to include “an individual,” and (b) plain meaning, regulation, and uniform case law all construe “individual” as a natural human being whether the litigant asserts the status or not.
A methodological caveat
The interpretive chain just described rests, at one link, on the ordinary English meaning of “individual.” The plain-meaning canon is well-established and the ordinary meaning of “individual” as “a single human being” is not currently under pressure in any direction that would affect tax administration. But ordinary-language meanings drift over time, and a foreclosure-verdict that rests partly on plain-meaning reasoning carries the corresponding exposure: if the ordinary meaning of “individual” shifted in a way that Treasury and the courts had not yet caught up to, the chain’s weakest link would be at that point. The verdict here is foreclosed under current doctrine — not by an unalterable express statutory definition. Adverse Review surfaces the distinction deliberately. A reviewer or future-Court that wished to test the chain’s robustness would press at the plain-meaning link first.
What older legal-dictionary history does and does not establish
Beers’s historical observation — that older legal dictionaries treated “person” as a status term encompassing a wide range of legal entities including slaves and corporations — is correct as historical lexicography. Bouvier’s Law Dictionary (1856) does define “person” broadly. The Roman-law persona / caput distinction is real intellectual history. The 19th-century antebellum slave-law cases had to work out how “person” interacted with slavery, property, contract, and criminal law in ways that produced a status-laden treatment of the term.
The relevance of that historical lexicography to modern American statutory construction is limited by the texts of the modern statutes themselves. Older legal-dictionary definitions are background to statutory interpretation; they do not override express statutory definitions. The IRC’s § 7701(a)(1) does not import 1856 Bouvier’s into the IRC’s “person” definition. The Dictionary Act does not defer to older common-law treatments of “person” — it provides its own default definition.
The argument from older legal-dictionary history therefore cannot displace the modern statute’s own definition. It can illuminate the conceptual history of the term, but it cannot make the term mean something different in a modern statute than the statute itself says it means.
The Dred Scott taxonomy
Beers offers a secondary line of historical support for the person / man distinction: a “two types of slaves” taxonomy he attributes to Dred Scott v. Sandford, 60 U.S. (19 How.) 393 (1857). On Beers’s reading (developed in Treatises 9 and 10), Dred Scott identifies two types of slave — chattel property with no civil rights, and persons recognized for civil purposes who must direct the fruits of their labor to a master. The second type is presented as the modern operative classification, applied to American citizens via the federal income tax.
Verification log V04 records the direct verification: the two-types taxonomy Beers attributes to Dred Scott is not in Taney’s opinion. Taney’s classifications are (a) Black/non-Black and (b) enslaved/free, not (a) chattel slave / (b) civil-purpose person directing labor. The “directs labor to the master” framing traces to Roman law and 19th-century treatise writers on slave law generally; it is being projected onto Dred Scott rather than read out of it. Dred Scott therefore does not support the secondary historical claim Beers makes for the person / man distinction.
Counter-authority
The courts that have heard this argument in its various forms have rejected it uniformly. United States v. Mundt, 29 F.3d 233 (6th Cir. 1994), rejected the natural-man argument as having “no conceivable validity in American law.” United States v. Slater, 545 F. Supp. 179 (D. Del. 1982), addressed a similar argument and labeled it “patently frivolous.” The Canadian decision in Meads v. Meads, 2012 ABQB 571 — while not binding in American courts — provides a thorough comparative survey of the natural-man / “Organized Pseudolegal Commercial Argument” ecosystem and traces its consistent rejection across common-law jurisdictions.
In the federal-tax context specifically, United States v. Sloan, 939 F.2d 499 (7th Cir. 1991), rejected a sovereign-citizen-style argument that the defendant’s status placed him outside the federal income tax’s reach. The Tax Court rejects natural-man status arguments with sufficient frequency that the rulings often appear in unpublished memoranda; the analytical posture across the cases is that the statute’s own definition controls and the litigant’s status assertions do not displace it.
The Tax Court’s published frivolous-positions list (issued periodically and maintained at IRS [Notice 2010-33] and successor notices) catalogues variants of the natural-man / non-person / declination argument as positions that will draw § 6673 sanctions. The doctrinal position is comprehensively foreclosed.
Verdict
Foreclosed. The argument fails at the statutory-construction layer, by an interpretive chain rather than by a single express definition. The IRC’s § 7701(a)(1) and the Dictionary Act at 1 U.S.C. § 1 both define “person” to include “an individual” alongside corporate and entity categories. Neither separately defines “individual.” Under the plain-meaning canon (Wisconsin Central, Taniguchi), the operative meaning of “individual” is its ordinary English sense — a single human being — which is the meaning Treasury Regulation 26 CFR § 1.1-1(a)(1) operationalizes and which federal courts have uniformly applied when the natural-man / declination argument has been pressed. The chain is doctrinally sufficient under current law; the foreclosure is real. The historical legal-dictionary lexicography Beers cites is correct as background but does not override the chain. The Dred Scott secondary support that Beers offers for the distinction is not in Taney’s opinion (V04). The federal courts that have heard the operative argument in its various forms have rejected it uniformly, and the position is on the Tax Court’s frivolous-positions list with attendant § 6673 sanction exposure.
The concept page on Beers’s person / man distinction treats the underlying vocabulary in greater historical depth. The existing finding on Federal jurisdiction requires individual consent addresses an adjacent move — the claim that federal courts lack jurisdiction over a natural person absent express consent — that fails for related reasons.