that it meant the opposite of the original amendment as it was submitted to the States by Congress, but that Secretary Knox counted Oklahoma as having approved the amendment. Benson also asserted, as an example of a state's violation of its own Constitution, laws, or procedural rules, the claim that the Tennessee State Constitution prohibited the legislature from acting on any proposed amendment to the U.S. Constitution submitted by Congress until after the next state legislative elections. According to Benson, the Tennessee legislature acted on the proposed 16th amendment the same month it was received (prior to any new state legislative elections). Legal status of Benson's claims The Benson book was published in 1985. The earliest reported court cases where the book was mentioned appear to be United States v. House and United States v. Wojtas. Benson testified unsuccessfully in the House case. In the latter case, defendant Wayne Wojtas was unsuccessful in his attempt to use Benson's theory to have his indictment for failure to file federal tax returns dismissed. In the case the judge ruled that Benson's evidence was inadmissible, stating that: Wojtas was convicted, sentenced to prison, and released in August 1986. Benson's claim was also rejected in Miller v. United States. The court stated, "We find it hard to understand why the long and unbroken line of cases upholding the constitutionality of the Sixteenth Amendment generally, Brushaber v. Union Pacific Railroad Company ... and those specifically rejecting the argument advanced in The Law That Never Was, have not persuaded Miller and his compatriots to seek a more effective forum for airing their attack on the federal income tax structure." The court then sanctioned the litigants for advancing a "patently frivolous" position. Similar "Sixteenth Amendment arguments" have been uniformly rejected by the courts in other cases including United States v. Thomas. In Thomas the court, in affirming the tax convictions of Kenneth L. Thomas, referred to Benson's book and noted that the errors found by Benson had already been investigated by Secretary of State Knox at the time of ratification of the Sixteenth Amendment, and had been determined to be insignificant. (See Tax protester constitutional arguments.) Arguments that the Sixteenth Amendment was not properly ratified were also rejected in Sisk v. Commissioner; United States v. Sitka; and United States v. Stahl. The non-ratification argument has also been deemed legally frivolous in Brown v. Commissioner and Lysiak v.