On July 7, 2006, the United States Tax Court found that Hovind was deficient in paying his federal income taxes in 1995–1997, totaling $520,099. The Tax Court ruled that the IRS had a valid lien on Hovind's property and said that Hovind's defense was based on "bizarre arguments, some of which constitute tax protester arguments involving excise taxes and the alleged '100% voluntary' nature of the income tax." With penalties, he owed $3.3 million for tax years 1998–2006 by 2013. Jo Hovind was ordered to pay $1.6 million.