On March 1, 1996, Hovind filed a Chapter 13 bankruptcy petition to avoid paying federal income taxes, claiming he was not a citizen of the United States and that he did not earn income. He claimed that as a minister, everything he owned belonged to God and he was not subject to paying taxes for doing God's work. On June 5, 1996, the Court dismissed Hovind's bankruptcy case, finding he had lied about his possessions and income. The court upheld the IRS's determination that his claim "was filed in bad faith for the sole purpose of avoiding payment of federal income taxes" and called Hovind's arguments "patently absurd". It also said that "the IRS has no record of the debtor ever having filed a federal income tax return."