an attempt by the IRS to tax beyond the explicit provisions of the law. Section 861 did not exist in the year 1917, when the Gould case was decided, and the Court was neither presented with nor decided the issue of whether domestic or foreign income is not taxable. The terms "domestic income" and "foreign income" do not appear in the case, and the court's main ruling in Gould v. Gould—that alimony was not taxable to the recipient under the Revenue Act of 1913—was overturned by a subsequent Act of Congress, the current version of which is found in the Internal Revenue Code of 1986 at . Court decisions The income taxes imposed on U.S. citizens and resident aliens are generally imposed under Subchapter A (not Subchapter N) of Chapter 1 of the Code. The income tax is imposed on the "taxable income" of individuals. The federal courts have consistently ruled that the argument that Section 861 excludes income of U.S. citizens and resident aliens from taxation is without legal merit. See Aiello v. Commissioner; Williams v. Commissioner; Corcoran v. Commissioner; Loofbourrow v. Commissioner.; United States v. Bell; Dashiell v. Commissioner.; Woods v. Commissioner; and Buckardt v. Commissioner. The argument that United States citizens and residents are not subject to tax on their wages, etc., derived from sources within the United States, and variations of this argument, have been officially identified as legally frivolous Federal tax return positions for purposes of the $5,000 frivolous tax return penalty imposed under Internal Revenue Code section 6702(a). The earliest reported case in which section 861 is raised as a limitation on the income tax is the 1993 case of Solomon v. Commissioner. In that case, the protester's primary argument was that "the State of Illinois is not part of the United States", and that he was therefore a resident alien, subject to taxation only under the provisions of §861. The court ruled: [P]etitioner's position is not bolstered by the regulations under section 861. To the contrary, section 861(a)(1) and (3) provides that interest from the United States and compensation for labor or personal services performed in the United States (with exceptions not applicable here) are items of gross income which shall be treated as income from sources within the United States. In Solomon, the court also stated: The record in this case establishes that petitioner had no interest in disputing either the deficiencies