tax threshold by taking up a simple living lifestyle. These individuals believe that their government is engaged in immoral, unethical or destructive activities such as war, and that paying taxes inevitably funds these activities. These methods differ from tax evasion in that they stay within the tax laws, and they differ from tax avoidance in that the goal is to pay as little tax as possible rather than to keep as much post-tax income as possible. Illegal Evasion A resister may decide to reduce their tax paid through illegal tax evasion. For instance, one way to evade income tax is to only work for cash-in-hand, therefore circumventing withholding tax. Redirection Some tax resisters refuse to pay all or a portion of the taxes due, but then make an equivalent donation to charity. In this way, they demonstrate that the intent of their resistance is not selfish and that they want to use a portion of their earnings to contribute to the common good. For instance, Julia Butterfly Hill resisted about $150,000 in federal taxes, and donated that money to after school programs, arts and cultural programs, community gardens, programs for Native Americans, alternatives to incarceration, and environmental protection programs. She said: I actually take the money that the IRS says goes to them and I give it to the places where our taxes should be going. And in my letter to the IRS I said: "I'm not refusing to pay my taxes. I'm actually paying them but I'm paying them where they belong because you refuse to do so." Refusing specific taxes Some resisters refuse to willingly pay only certain taxes, either because those taxes are especially noxious to them, or because they present a useful symbolic target, or because they are more easily resisted. For instance, in the United States, many tax resisters resist the telephone federal excise tax. The tax was initiated to pay for the Spanish–American War and has frequently been raised or extended by the government during times of war. This made it an attractive symbolic target as a "war tax". Such refusal is relatively safe: because this tax is typically small, resistance very rarely triggers significant government retaliation. Phone companies will cooperate with such resisters by removing the excise tax from their phone bills and reporting their resistance to the government. Refusing to pay The most dramatic and characteristic method of tax resistance is to