In "Scott", the court noted that an undercover government agent had sworn out an affidavit regarding the agent's infiltration into a "tax-protester" organization. The case involved James Walter Scott, the leader of that organization. Scott had failed to file tax returns from 1969 to 1972, based on Constitutional arguments against the validity of the income tax. Scott argued unsuccessfully that the Sixteenth Amendment was not properly ratified, that federal reserve notes were not legal tender and that he was not required to report their receipt as income, and that he was not required to file tax returns if he felt they would incriminate him. The United States Court of Appeals for the Ninth Circuit upheld Scott's conviction.