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SUPREME COURT, STATE OF COLORADO
Colorado State Judicial Building2 East
14
u,
Avenue, Denver, Colorado 80203
PETITIONERS:
Amalia CerriIIo; Luis Noriega, onbehalf
of
himself as a class representative; John Doe, onbehalf
of
himself as a class representative; Frank Doe, onbehalf
of
himself as a class representative; and RobertDoe,
on
behalf
of
himself as a class representative
RESPONDENTS:
Kenneth R. Buck, in his officialcapacity as District Attorney for the Nineteenth JudicialDistrict; and JOHN COOKE, in his official capacity asWeld County Sheriff
AMICUS CURIAE:
American GI Forum, League
of
United Latin American Citizens, Colorado ImmigrantRights Coalition
ATTORNEY FOR AMICUS:
Nina Perales:
Pro hac vice application pending
Address: MALDEF, 110 Broadway, Suite 300San Antonio, Texas 78205Phone Number: (210) 224-5476
FAX
Number: (210) 224-5382Email: nperales@maldef.orgAtty. Reg. #: Texas Bar No. 24005046Sponsoring Attorney: Manuel
J.
SolanoAddress: Solano Law Offices12000 North Washington Suite 310Thornton, Colorado 80602Phone Number: (303) 457-2000Att. Reg. #: 007646
... COURTUSEONLY ...
Case No. 09SC341
AMICUS CURIAE BRIEF
OF
AMERICAN GI FORUM, LEAGUE OF UNITED LATINAMERICAN CITIZENS AND COLORADO IMMIGRANT RIGHTS COALITIONIN SUPPORT
OF
PETITIONERS-APPELLEES AMALIA CERILLO, ET AL.
 
TABLE
OF
CONTENTS
TABLE OF AUTHORITIES
iii
STATEMENT
OF
INTEREST
OF
AMICUS CURIAE
2
The
American
GI Forum
2The League
of
United Latin American Citizens 3Colorado Immigrant Rights Coalition 3SUMMARY
OF
ARGUMENT 4ARGUMENT 5
I.
FILING
INDIVIDUAL INCOME TAX RETURNSSERVES A LEGAL, ECONOMIC,
AND
CIVICPURPOSE IN OUR NATION, REGARDLESS
OFTHE
IMMIGRATION STATUS
OF
WAGE EARNERS 5
A.
The
Internal Revenue Service places a statutoryDuty upon wage-earners to file individual income
tax
returns
and pay their fair share
of
taxes in
order
to prevent an underground economy 5
B.
The
ITIN System Protects U.S. Citizen and Work-
Authorized Immigrants 9
C.Filing income tax
returns
also helps unauthorizedworkers who hope to achieve full citizenship
12
II. TAX PREPARERS PROVIDE A NECESSARYAND CONFIDENTIAL SERVICE
FOR
IMMIGRANT TAX FILERS
NA
VIGATING
THE
COMPLEX U.S. TAX SYSTEM 14
 
III.
IMPROPER
USE OF TAX RECORDS OF
U N D O C U M E N T E D I M M I G R A N T S ~ L L F O R C E
 
THE CREATION
OF
AN
UNDERGROUND ECONOMY
AND
THREATENS THE CONFIDENTIALITY OF
THE
MAJORITY
OF
CITIZEN TAX RECORDS
16
CONCLUSION 18
ii
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