Also in 1973, a disbarred attorney named Jerome Daly lost an appeal on his conviction for willfully failing to file federal income tax returns. In rejecting Daly's appeal, the United States Court of Appeals for the Eighth Circuit noted that one of Daly's contentions involved his "seemingly incessant attack against the federal reserve and monetary system of the United States. His apparent thesis is that the only 'Legal Tender Dollars' are those that contain a mixture of gold and silver and that only those dollars may be constitutionally taxed. This contention is clearly frivolous."