Petition — Gust v. United States

Office -S:oreme Corrt, U.S.

80 1 Fins w

é 2 APR 6 1981

O e ALEXANC Zé L. STEVAS,

In The

Supreme Court of the United States

MAY TERM 1981

DAVID H. GUST,

Petitioner,

Uv.

UNITED STATES OF AMERICA,

Respondent.

PETITION FOR A WRIT OF CERTIORARI

TO THE SECOND CIRCUIT COURT OF APPEALS

DAVID H. GUST

399 Parma Center Road

Hilton, New York 14468

Telephone: (715) 722-1665

QUESTIONS PRESENTED

1. Whether the petitioner received a fair trial and was con-

victed with truthful evidence.

2. Whether the IRS notice to the taxpayer indicated a rejec-

tion of petitioner’s return.

3. Whether the petitioner’s tax return accepted initially by

the IRS was, as a matter of law, a return. Stated another way,

when does a tax form become a tax return.

4. Whether the law is clear and interpretations are consistent.

TABLE OF CONTENTS

mee Authors. .... 6 ons 60 05 Oke

EPO. wks. a ve ws sc aos ob a on a ee

ANON ssc SS eaves. ee eee

feemetiones Preeemted. ...... 055 «<5 15ee5 ee

eebembent of the Case. ...../.6i4 0 a eee eee

pentemnent OF Facts... ook sss nis «+ hee eee

POINT I — A citizen of the United States of America is

denied a fair trial with truthful evidence when the

Government submits, as evidence to the jury, in-

formation that is contrary to the Government’s

knowledge of the matter.............0000 0c eee

POINT II - The courts cannot require the taxpayer to act

in compliance with official notice from the Internal

Revenue Service and then turn on the taxpayer for

GOUT GO. cc cence ses ade ee eee

POINT III — In computing a tax liability from the in-

formation on the petitioner’s return, the Internal

Revenue proved it was a return thereby requiring no

action by petitioner... 0.0.0.0... 0.0.00. eee eee

POINT IV - A law so vague and ambiguous that men of

good faith reach differing conclusions as to what is

required or what is prohibited is no law at all, it

creates no office, establishes no authority, settles no

disputes, and leaves the parties where it found them. It

is void not from the date of its being declared so, but

from the date of its inception. 16 Am Jur 2d Sec. 177 . .

rr rr fe

Conclusion............ 000 eee eee eee ee ennnnes

co 4 =)

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Page

APPENDIX

Order of United States Court of Appeals Second Circuit

I PE Ne hi ore eh ins A-l

Oliieial Motioe rom IRS... oc kav ces eces A-4

Affidavit of Robert T. Mulig...................... A-5

AMidavit of Robert T. Mulie................0c0005 A-6

Verification of Contributions..................... AT

Government's Misrepresentation of Contributors ...... A-10

TABLE OF AUTHORITIES

Cases: Page

Miranda v. Arizona, 342 US 486 .......... 0.0... eee 4

United States v. Long, 618 F.2d 74 (9th Cir. 1980) ...... 6

United States v. Porth, 426 F.2d 519 (10th Cir. 1970)... . 6

United States v. Smith, 618 F.2d 280 (5th Cir. 1980)... .. 7

Statutes:

SR as ale a aS re ER Ok oe ee 2,5

RM a PE sore es 5k Ae Se AAR ee > en ee 2

United States Constitution, Article 1, section 9,

I Dy oe 5 es ee ee ls ed Rome eG 6

eee PN ETAT See's oe oe eb hae SBA ESS 7

In The

Supreme Court of the United States

MAY TERM 1981

No.

DAVID H. GUST,

Petitioner,

Vv,

UNITED STATES OF AMERICA,

Respondent.

PETITION FOR A WRIT OF CERTIORARI

TO THE SECOND CIRCUIT COURT OF APPEALS

To the Honorable, the Chief Justice and Associate Justices of the

Supreme Court of the United States

David H. Gust Petitioner herein pray that a Writ of Certiorari

issue to review the judgment entered by the United States Court

of Appeals for the Second Circuit on March 2, 1981 affirming the

judgment of the United States District Court for the Western

District of New York.

OPINION BELOW

The United States Court of Appeals for the Second Circuit

found as a matter of fact that Petitioner was not “trapped” as a

result of the Service's (IRS) notification in response to his 1975

“return”. Further the returns failed to provide any basis upon

which appellant’s tax liability could be computed. Other argu-

ments are equally without merit. Judgment Affirmed. See

Appendix A-1.

JURISDICTION

Jurisdiction of this Court is invoked under Title 26 USC 1254

(1)

QUESTIONS PRESENTED

1. Whether the petitioner received a fair trial and was con-

victed with truthful evidence.

2. Whether the IRS notice to the taxpayer indicated a rejec-

tion of petitioner’s return.

3. Whether the petitioner’s tax return accepted initially by

the IRS was, as a matter of law, a return. Stated another way,

when does a tax form become a tax return.

4. Whether the law is clear and interpretations are consistent.

STATEMENT OF THE CASE

Petitioner seeks review of the Judgment of the United States

Court of Appeals for the Second Circuit entered on March 2,

1981, affirming the conviction entered in the United States

Court for the Western District of New York. On July 24, 1980,

after a three-day trial, the jury found petitioner guilty of three

counts of willful failure to file individual tax returns for the

calendar years 1975, 1976 and 1977 in violation of Title 26, USC

7203. Petitioner was also found guilty of willfully filing false

withholding statements in violation of Title 26 7205 for 1976,

1977, and 1978.

On October 14, 1980, Judge Burke sentenced petitioner to 6

months and | day for each count and $1,000.00 for each count of

willfully failing to file a tax return.

STATEMENT OF FACTS

Petitioner filed his 1975 Federal Income Tax at the IRS

Service center at Andover, Mass. The Tax authorities at Andover

received the return, reviewed it, computed the tax from the

information on the return and sent a notice to the petitioner

entered as evidence and shown as A-1 in the Addendum to this

petition. That official response to the filing of petitioner’s return

never indicated the return was unacceptable or that further

action was needed. To the contrary, the bottom line of the official

notice clearly states in bold letters

THIS NOTIFICATION REQUIRES

NO ACTION BY YOU.

Acting on the information the IRS supplied, in an unsolicited

manner, petitioner took no action nor did petitioner have any

reason to make any changes in his relationship with the IRS. On

March 25, 1980, the U.S. Attorney repudiated that official docu-

ment by filing a six count information clearly stating much

action should have been taken. The information charged that the

return accepted for 1975 was not a return at all and petitioner

was a criminal for not filing it. Additionally the returns

petitioner had filed for 1976 and 1977 were not returns and this

was all in criminal violation of Federal Law. Furthermore there

were three counts of willfully filing false withholding certifi-

cates with petitioner’s employer for 1976, 1977, and 1978. During

the trial it was shown that petitioner had been deceived by

David Fields who, as a warrant agent, acting in a position of

created authority and under color or law, attempted to defraud

petitioner out of $950.00 in the name of taxes. Answering a com-

plaint filed by petitioner the Tax Officials confessed they used

fictitious names in these matters. See Appendix A-5 and A-6.

As a consequence of ‘filing a valid complaint against a tax

official, at least the name of one who pretended to be, petitioner

is labeled a protestor and has been prosecuted.

In obtaining a conviction the prosecutor had admitted, as

evidence to the jury, information that was contrary to the truth

as the government knew it to be. Contrary to the computation of

petitioner’s tax as done by the IRS, the Appeals Court found no

basis for computing a tax from the return filed. However, the

Appeals Court did state their opinion was not formal and shall

not be cited or otherwise used in unrelated cases.

POINT I

A citizen of the United States of America is denied a fair

trial with truthful evidence when the Government submits, as

evidence to the jury, information that is contrary to the

Government’s knowledge of the matter.

To verify petitioner’s contributions for the years in question,

the Government issued subpoenas to some of the organizations

petitioner supported as evident in Appendix A-7 through A-9

and summed as fo!lows:

1975 1976 1977

$2,820.00 $2,175.25 $2,878.00

However, the calculated petitioner’s taxes showing contribu-

tions misrepresented as evident in Appendix A-11.

1975 1976 1977

$170.00 $208.00 $142.00

To argue the subpoenaed information was not essential as

evidence in computing petitioner’s tax liability is to accuse the

Government of issuing vain and useless subpoenas. Further-

more, this technique of withholding in excess of 90% of the

known entries in a given category is not allowed to the taxpayer.

Since it is a settled point of law that a wrongful act is deter-

mined by the nature of the act and not the identity of the actor,

petitioner urges this Court to forcefully strike down this

wrongful action and the convictions obtained from it just as it

did in the landmark case of the Miranda decision. Miranda v

Arizona, 342 US 436.

POINT II

The courts cannot require the taxpayer to act in com-

pliance with official notices from the Internal Revenue

Service and then turn on the taxpayer for doing so.

After the petitioner’s tax return was received at the service

center at Andover Mass., the tax authorities reviewed the

return, computed a tax liability from the information on the

return and sent the petitioner a notice showing the results of

their calculations. The United States Court of Appeals for the

Second Circuit erred on this point finding:

(petitioner) “failed to provide any basis upon which

appellant’s tax liability could be computed, and hence

failed to satisfy the minimum standard for “returns”

ae the meaning of §7203 of the Internal Revenue

e.

The official notice issued in response to receiving petitioner’s

tax return shows the Internal Revenue Service computed

petitioner’s tax return, by their own choice, and notified

petitioner of the official action taken by the Internal Revenue

Service as a result of receiving petitioner’s tax return. Further-

more, the bottom line of the official notice from the Internal

Revenue Service clearly states in bold capital letters,

THIS NOTIFICATION REQUIRES

NO ACTION BY YOU.

Petitioner respectfully submits there is no reasonable inter-

pretation of the official statement above that can be construed to

mean;

“we have rejected your return and you must take action

to file an acceptable return.”

The plain language of the official notice to this petitioner

clearly and unambiguously declares nothing is lacking which

requires immediate attention! Even if the Internal Revenue

Service was wrong in issuing their official notice to the

petitioner, which they were not, petitioner had no reason to

believe his return had been rejected. Subsequent returns were

filed and never did the Internal Revenue Service ever hint to this

petitioner that the official notice was no longer valid. Even if the

official notice to this petitioner were to be determined to be in

error, ex post facto, that would not make the party relying on

that official notice a criminal ex post facto. United States Consti-

tution, Article I, Section 9, paragraph 3.

POINT III

In computing a tax liability from the information on the

petitioner’s return, the Internal Revenue proved it was a

return thereby requiring no action by petitioner.

In United States v. Porth, 426 F.2d 519, 523 (10th Cir. 1970)

the Court stated:

a form that does not contain sui“:cient information on

which a tax liability can be computed is not a return.

That being valid as a definition of a return then

a form that does contain sufficient information on which

a tax liability can be computed is a return.

The value of this definition is its simplicity and its

mathematical irrefutability. It does not turn on intent or inter-

pretation. This point is well supported in United States v. Long,

618 F.2d 74 (9th Cir 1980). Long had entered zeros in various

places on his tax return. In reversing Long’s conviction for will-

ful failure to file (26 USC 7203) the Appeals Court stated:

“The IRS could calculate assessments from Long’s zeros

just as it could if Long had entered other numbers.”

Although the IRS had not calculated an actual tax liability in

the Long case as the IRS did in this case, the Court properly

stated it could have been done. As a high school student knows,

zeros, like whole positive integers, have specific value. In our

check book, zeros tell us something. In this case the numbers

were whole positive integers and the action of the Internal

Revenue Service in sending their official notice to the petitioner

was both proper and in good faith.

POINT IV

A law so vague and ambiguous that men of good faith reach

differing conclusions as to what is required or what is

prohibited is no law at all, it creates no office, establishes no

authority, settles no disputes, and leaves the parties where it

found them. It is void not from the date of its being declared

so, but from the date of its inception. 16 Am Jur 2d Sec. 177

Whereas the official notification sent to this petitioner from

the Internal Revenue Service is soundly based on the reasoning

of Long in defining a tax return, there is direct and total dis-

agreement in the Circuit Courts.

In United States v. Smith, 618 F.2d 280 (5th Cir. 1980), this

Court squarely contradicts Long on the definition of the return.

Although it is laymen who are required to file a return, it is

experts who cannot agree on what the return is.

SUMMARY

While there are direct Judicial contradictions of the definition

of the return petitioner was criminally convicted of willfully

failing to file, one critical and controlling point emerges without

challenge. Petitioner never voluntarily violated the law he was

convicted of violating. It is an absolute certainty that filing a

“return,” whatever that may be, is not a voluntary act. Like

death itself, filing a tax return is a compelled matter over which

petitioner does not exercise a free and unfettered choice. Nor

was this petitioner entitled to a preliminary hearing on any of

the charges. Instead petitioner was forced, without aid of legal

counsel, into an uncharted sea of legality, and has been ship-

8

wrecked on the hidden shoals of conflicting information and

opinion from both the Internal Revenue Service** and the

Judiciary itself.

CONCLUSION

For all the foregoing reasons petitioner respectfully urges this

Court to review this matter and issue clear and unambiguous

definitions that will settle the contradictions within the Circuits

and relieve the people from criminal prosecution based on the

taxpayers reliance on information the IRS provides.

Respectfully submitted,

DAVID H. GUST

399 Parma Center Road

Hilton, New York 14468

Telephone: (716) 722-1665

**Petitioner has served notice on the Commissioner of the Internal Revenue

demanding specifications, from the Commissioner, that will constitute an

“acceptable” return. The lack of the courtesy of even an acknowledgement of

receiving the notice may indicate the Tax Authorities prefer prosecution to

cooperation.

APPENDIX

A-l

ORDER OF UNITED STATES COURT OF APPEALS

SECOND CIRCUIT DATED MARCH 2, 1981

UNITED STATES COURT OF APPEALS

Second Circuit

N.B. Since this statement does not constitute a formal opinion of

this court and is not uniformly available to all parties, it shall

not be reported, cited or otherwise used in unrelated cases before

this or any other court.

a Stated Term of the United States Court of Appeals, in and for

the Second Circuit, the United States Court House, in the City of

New York, on the 2nd March, one thousand nine hundred and

eighty-one.

PRESENT:

HONORABLE WILFRED FEINBERG

Chief Judge

HONORABLE JAMES L. OAKES

Circuit Judge

HONORABLE EDWARD R. NEAHER*

District Judge

UNITED STATES OF AMERICA,

Plaintiff-A ppellee,

DAVID H. GUST,

Defendant-A ppellant.

80-1412

Appeal from the United States District Court for the Western

District of New York.

*l'nited States District Judge for the Eastern District of New York, sitting

by designation.

A-2

Order of the United States Court of Appeals

Second Circuit dated March 2, 1981

This cause came on to be heard on the transcript of record from

the United States District Court for the Western District of New

York, and was argued by appellant pro se and by counsel for

appellee.

ON CONSIDERATION WHEREOF, it is now hereby ordered,

adjudged and decreed that the judgment of said District Court be

and it hereby is AFFIRMED.

David H. Gust appeals from a judgment of conviction following

a jury trial before Judge Harold P. Burke in the United States

District Court for the Western District of New York. Gust was

found guilty of three counts of failure to file a valid tax return,

in violation of 26 U.S.C. §7203, and three counts of supplying

false information to his employer concerning tax exemptions, in

violation of 26 U.S.C. §7205.

He was sentenced to a term of imprisonment of six months and

one day on each count, to be served concurrently, and fined

$1,000 on each of the three counts charging violation of 26 U.S.C.

§7203.

We find no merit in appellant’s argument that he did file valid

tax returns for the years 1975, 1976, and 1977. These “returns,”

with their “figures[s] expressed in Constitutional dollars of gold

and silver” and their assertion of “objection self-incrimination,”

failed to provide any basis upon which appellant’s tax liability

could be computed, and hence failed to satisfy the minimum

standards for “returns” within the meaning of §7203 of the

Internal Revenue Code. See, e.g., United States v. Porth, 426

F.2d 519, 523 (10th Cir.), cert. denied, 400 U.S. 824 (1970). Ap-

pellant’s reliance on United States v. Long, 618 F.2d 74 (9th Cir.

1980), is of no avail, because in that case the returns alleged to

have been filed had zeros in the entries for income, exemptions,

and so forth, thereby providing a basis for the calculation of tax.

A-3

Order of the United States Court of Appeals

Second Circuit dated March 2, 1981

In any event, we express no view as to the soundness of the

decision in Long.

We also reject appellant’s contention that he was “trapped” as

a result of the Service’s notification, in response to his 1975

“return,” that he had no tax liability for that year and that the

notification “requires no action by you.” Appellant claims he

was entitled to rely on this notification as a form ot approval of

his “return,” justifying his submission of similar “returns” in

1976 and 1977. The issue of appellant’s good-faith reliance was

adequately presented to the jury in the judge’s charge with

respect to wilfulness, a charge in which we find no reversible

error.

We have considered appellant’s other arguments and find

them equally meritless. Accordingly, the judgment of conviction

is affirmed.

ls) WILFRED FEINBERG

Wilfred Feinberg, Chief Judge

ls) JAMES L. OAKES

James L. Oakes, Circuit Judge

ls) EDWARD R. NEAHER

Edward R. Neaher, District Judge

UNITED STATES COURT OF APPEALS

_ FILED

MAR 2 1981

A. DANIEL FUSARO, CLERK

SECOND CIRCUIT

A-4

OFFICIAL NOTICE FROM IRS

Department of the Treasury Date of This Notice

Internal Revenue MAY 17, 1976

Service Center Taxpayer Identifying Number

ANDOVER, MA. 01812 050-30-2998

AU 7618 Document Locator Number

16211-108-30974-6

DAVID H. GUST Form Number

399 PARMA CTR RD 1040

HILTON NY 14468 Tax Period Ended

DEC. 31, 1975

NOTICE TO TAXPAYER TAX COMPUTATION

WE COMPUTED YOUR TAX YOUR TOTAL

BASED ON THE INFORMATION INCOME TAX . os .ivseeeeeee $.00

YOU FURNISHED ON YOUR

FORM 1040.

HERE IS OUR REPORT — THE TAX WITHHELD BY YOUR

FIGURES SHOWN AT THE RIGHT. EMPLOYERS....... $.00

THIS INFORMATION IS FOR OTHER TAX

YOUR RECORDS. — THISIS NOT YOUPAID......... 00

A BILL.

THIS NOTICE IS NOT THE RE- TOTAL CREDIT FOR

SULT OF AN AUDIT OF YOUR RE- PAYMENTS MADE .......... 00

TURN. WHEN WE SELECT A RE-

TURN FOR AUDIT, WE NOTIFY

THE TAXPAYER. REFUND .......002 NONE

—THIS NOTIFICATION REQUIRES NO ACTION BY YOU—

A-5

AFFIDAVIT OF ROBERT T. MULIG

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF NEW YORK

DAVID H. GUST,

Plaintiff,

against

DAVID FIELDS,

Defendant.

CIVIL ACTION FILE

NO. 79-16

STATE OF NEW YORK \ et

COUNTY OF ALBANY z

AFFIDAVIT

ROBERT T. MULIG, being duly sworn, deposes and says:

1. Iam an Assistant Attorney General on the staff of Robert

Abrams, Attorney General of the State of New York, attorney

for the defendant herein. I make this affidavit in opposition to

plaintiff's motion for summary judgment. I have been assigned

this matter from the outset and I am fully familiar with the

facts and circumstances.

2. As I stated on February 12, 1979 at oral argument of the

related case of Gust v. Connors, the defendant David Fields was

not personally served nor could he be so served. I am advised by

the Tax Compliance Bureau that this defendant’s name is ficti-

tious and is used to identify particular forms mailed to tax-

payers in order to facilitate handling of correspondence when a

reply is received.

A-6

AFFIDAVIT OF ROBERT T. MULIG

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF NEW YORK

DAVID H. GUST,

Plaintiff

against

RONALD BRADSHAW, JR.,

Defendant.

CIVIL ACTION FILE

NO. 78-826

STATE OF NEW YORK \ |

COUNTY OF ALBANY SS.:

AFFIDAVIT

ROBERT T. MULIG, being duly sworn, deposes and says:

1. Iam an Assistant Attorney General on the staff of Robert

Abrams, Attorney General of the State of New York, attorney

for the defendant herein. I make this affidavit in opposition to

plaintiff's motion for summary judgment. I have been assigned

this matter from the outset and I am fully familiar with the

facts and circumstances.

2. As I stated on February 12, 1979 at oral argument of the

related case of Gust v. Connors, the defendant Ronald Bradshaw,

Jr., was not personally served nor could he be so served. I am ad-

vised by the Tax Compliance Bureau that this defendant’s name

is fictitious and is used to identify particular forms mailed to

taxpayers in order to facilitate handling of correspondence when

a reply is received.

A-7

VERIFICATION OF CONTRIBUTIONS

District Director

Internal Revenue Service

Attn: Mr. William Schirmer:

Dear Sir:

The following is a list of the amounts and the dates of the

contributions made by Mr. David H. Gust to Camp Cherth of

W.N.Y.

ls) RICHARD C. MAYO

Treasurer

1975 $140.00

1976 $130.00

1977 $120.00

Total $390.00

HCJB

August 8, 1978

Mr. William R. Schirmer

Intelligence Division

Internal Revenue Service

100 State Street

Rochester, New York 14614

Dear Mr. Schirmer:

Re: David H. Gust

Hilton, New York 14468

In reply to your letter of August 2, enclosed from our computer

history records are detail lists of check contributions showing

date, receipt number, amount, account credited, and account

name for 1975, 1976, and 1977, viz.

1975 Total $390

1976 Total 390

1977 Total 360

Relative to contributions in a form other than cash or check, we

A8

Verification of Contributions

find no record of having issued to Mr. Gust an “Official Memo

Receipt” from this office.

Sincerely yours,

ls) A.E. ERICSON

Arthur E. Ericson

Assistant treasurer

AEE/Ift

Enclosures

BRIGHTON COMMUNITY CHURCH

420 WINTON ROAD NORTH

ROCHESTER, NEW YORK

AREA CODE 716 - 482 - 6069

Dr. W. Millar Crawford, Pastor

Theodore S. Brewer, Assistant Pastor

David P. Blackmore, Dir. of Christian Ed.

John D. Zimmerman, Church Administrator

August 25, 1978

Mr. William R. Schirmer,

Special Agent

Dept. of Treasury

100 State St.

Rochester NY 14614

Dear Sir:

Enclosed are copies of statements of contributions issued to Mr.

& Mrs. David Gust for the years of 1976 and 1977. I cannot

produce such a statement for 1975. However, I have recon-

structed, from what information I have available, a partial

statement for that year. Work sheets for the last two months

and the copies of the annual statements are missing. I fear they

were lost when part of the basement was flooded during last

spring’s thaw.

A-9

Verification of Contributions

We have no specific records as to non-cash contribution, but Mr.

Gust has felled several iarge trees on the churches new property.

Sincerely,

ls) JOHN D. ZIMMERMAN

John D. Zimmerman

JDZ:pt

Enc. ;

1975 Total $2,050.00

1976 Total $1,505.25

1977 Total $1,971.00

YOUTH FOR CHRIST CAMPUS LIFE

GREATER ROCHESTER

150 WINTON ROAD NORTH

(716)482-7540

August 18, 1978

Mr. William R. Schirmer

Department of the Treasury

100 State St.

Rochester, N.Y. 14614

Dear Mr. Schirmer:

The following is a list of all contributions that our records show

were made to us in the vears 1975, 1976, and 1977 by David H.

Gust, 399 Parma Center Rd., Hilton, N.Y., in answer to your

request of 8/2/78.

1975 Total $240.00

1976 Total $290.00

1977 Total $655.00

I hope I have given you all the information you need, and that it

will be helpful to you.

Sincerely,

ls); KAREN E. ANDREWS

Karen E. Andrews

Financial Secretary

A-10

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xe]

awodu| ajqexe)

suondwex 3

uoIjINpeg PseDUe}S

voRINpag Peziwa}| SSz]

awo2u) Ssos5 paysnipy

aWwODU| 0} SJUaWYSMIpy -Ssz]

awo du) SS0J5)

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snuog

sazem SSol5)

ISNd “H GIAVG 40 AIN3IDISIG XV GN 3NCONI SSOUD 40 NOLLVINANOD

A-13

Governments Misrepresentation of Contributions

A a{Mpayrs ajey xe] wi Papnjoui — ONO] JO JuNOWY jayDeIg O18Z

Aayesedas Burj pausew — , anpayds peasy (Q)

Mayesedas Burry pausew — 4 ajnpayds peasy (9)

Mayesedas Buijly pauuew — 4 ajnpayrg ajey xe) Bursn — 9 ajnpayds uo payndwo) (g)

Mayesedas Burpy pausew — 4 anpayIs ajey xej usm — 9 ajnpayrs uo payndwoy (y)

(panuyued) ISAS “H GIAWG 40 AIN3IDIIIG XV GNY JWOINI SSOUS 40 NOILWINdWOD