25 avr. 1951 - Kellems v. United States, 97 F. Supp. 681 (D. Conn. 1951) -In 1948, Kellems refused to collect withholding taxes from her employees on behalf of the government, stating, "If they wanted me to be their agent, they'd have to pay me, and I want a badge."

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The withholding feature of the income tax is a still more clear-cut instance of involuntary servitude. For as the intrepid Connecticut industrialist Vivien Kellems argued years ago, the employer is forced to expend time, labor, and money in the business of deducting and transmitting his employees' taxes to the federal and state governments — yet the employer is not recompensed for this expenditure

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