999 F.2d 1255
                   UNITED STATES of America, Appellee,
   Gregory L. GERADS, individually;  Dorothea A. Gerads, individually,
Gregory L. Gerads, as Trustee for Rocky Hills;  Dorothea A. Gerads;  Ruth M.
  Bloch;  Jeffrey J. Gerads;  Beth M. Gerads;  Peggy E. Gerads, Defendants.
                               No. 93-1449.
                     United States Court of Appeals,
                              Eighth Circuit.
                        Submitted June 29, 1993.
                         Decided July 26, 1993.
                     Rehearing Denied Aug. 30, 1993.

	Gregory L. Gerads and Dorothea A. Gerads, Freeport, MN, for
	Gary R. Allen, Dept. of Justice, Washington, DC, for appellee.

	Before FAGG, BEAM, HANSEN, Circuit Judges.

	Gregory L. Gerads and Dorothea A. Gerads, husband and wife
(appellants), appeal from the district court's [FN1] orders granting the
government's motions for summary judgment in this action to recover back
income taxes.  We affirm.

	FN1. The Honorable Harry H. MacLaughlin, United States District
Judge for the District of Minnesota.

	Appellants are tax protestors who have refused to file or pay
federal income taxes since 1976.  They reside on a tract of farmland in
Freeport, Minnesota, in Stearns County.  On December 5, 1988, the IRS sent
appellants Notice of Deficiency letters for the tax years 1976 through
1983.  On April 18, 1989, the government assessed federal income taxes,
additions to tax, and statutory interest against appellants for these tax
years.  The government filed notice of the assessments and demanded
payment.  Appellants did not contest the deficiencies, and, other than
Gregory's payment of $449.63, they have not attempted to satisfy their tax
liability.  The government then filed notices of federal tax lien against
the farmland with the Stearns County Recorder in the names of appellants,
Rocky Hills, as nominee of Gregory L. Gerads, and Sunrise Living Trust, as
nominee of both appellants.  On July 24, 1991, the government commenced
this action, under 26 U.S.C. ss 7401-03, to (1) reduce to judgment the
income taxes it had assessed against appellants for the years 1976 through
1983;  (2) set aside as fraudulent appellants' purported conveyance of the
farmland to the two "trusts";  (3) quiet title to the property;  and (4)
eject any and all inhabitants from the property to facilitate foreclosure
of its tax liens.  Thereafter, the government moved for summary judgment.
The district court granted the motions and the relief the government
requested. This appeal followed.
	The district court correctly granted the government's motions for
summary judgment because appellants did not contest the factual bases for
the assessments and because their legal arguments attacking the court's
jurisdiction and the validity of the assessments were clearly meritless.
See Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 2552, 91
L.Ed.2d 265 (1986).  The arguments they advance on appeal are also
frivolous.  First, the Certificates of Assessments and Payments submitted
by the government here are sufficient to establish the validity of the
assessments.  See Geiselman v. United States, 961 F.2d 1, 5-6 (1st Cir.)
(per curiam), cert. denied, --- U.S. ----, 113 S.Ct. 261, 121 L.Ed.2d 191
(1992).  Second, appellants' claim that the government failed to establish
that the district court had "inland jurisdiction," and therefore, the case
against them should have been dismissed is meritless.  United States
v. Saunders, 951 F.2d 1065, 1068 (9th Cir.1991).  Third, we have rejected,
on numerous occasions, the tax-protestor argument that the federal income
tax is an unconstitutional direct tax that must be apportioned.  See,
e.g., Lively v. Commissioner, 705 F.2d 1017, 1018 (8th Cir.1983) (per
curiam).  Likewise, we have held that wages are within the definition of
income under the Internal Revenue Code and the Sixteenth Amendment, and
are subject to taxation. Denison v. Commissioner, 751 F.2d 241, 242 (8th
Cir.1984) (per curiam), cert. denied, 471 U.S. 1069, 105 S.Ct. 2149, 85
L.Ed.2d 505 (1985). Appellants' claim that payment of federal income tax
is voluntary clearly lacks substance.  See Newman v. Schiff, 778 F.2d 460,
467 (8th Cir.1985).  And, finally, we reject appellants' contention that
they are not citizens of the United States, but rather "Free Citizens of
the Republic of Minnesota" and, consequently, not subject to taxation.
See United States v. Kruger, 923 F.2d 587, 587-88 (8th Cir.1991)
(rejecting similar argument as "absurd").
	The government requests that we assess $1,500 in sanctions
against appellants for bringing this frivolous appeal based on
discredited, tax- protestor arguments.  Because the arguments appellants
advance for reversal are clearly lacking in merit and frivolous, we grant
the government's motion for $1,500 in sanctions pursuant to 28 U.S.C. s
1912 and Federal Rule of Appellate Procedure 38.  See United States
v. Carter, 988 F.2d 68, 69-70 (8th Cir.1993) (per curiam) ("As the
arguments raised in this appeal are frivolous, and we have many times so
held, we award a sanction in the form of damages in the amount of $1500
against appellants.");  Kruger, 923 F.2d at 588 ("Because this appeal is
utterly frivolous, the government's motion for sanctions in the amount of
$1,500 is granted.").
	Accordingly, we affirm the district court's judgment and grant the
government's motion for sanctions in the amount of $1,500.