This post is from an article writte for Wall Street Journal by Paul Moreno.  A short bio appears at the bottom of this article.



OPINION
 July 6, 2012, 7:14 p.m. ET
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Paul Moreno: A Short History of Congress's Power to Tax
The Supreme Court has long distinguished the regulatory from the taxing power..

By PAUL MORENO
In 1935, Secretary of Labor Frances Perkins was fretting about finding a constitutional basis for the Social Security Act. Supreme Court Justice Harlan Fiske Stone advised her, "The taxing power, my dear, the taxing power. You can do anything under the taxing power."

Last week, in his ObamaCare opinion, NFIB v. Sebelius, Chief Justice John Roberts gave Congress the same advice—just enact regulatory legislation and tack on a financial penalty, as in failure to comply with the individual insurance mandate. So how did the power to tax under the Constitution become unbounded?

The first enumerated power that the Constitution grants to Congress is the "power to lay and collect taxes, duties, imposts, and excises, to pay the debts and provide for the common defense and general welfare of the United States." The text indicates that the taxing power is not plenary, but can be used only for defined ends and objects—since a comma, not a semicolon, separated the clauses on means (taxes) and ends (debts, defense, welfare).


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This punctuation was no small matter. In 1798, Pennsylvania Rep. Albert Gallatin said that fellow Pennsylvania Rep. Gouverneur Morris, chairman of the Committee on Style at the Constitutional Convention, had smuggled in the semicolon in order to make Congress's taxing power limitless, but that the alert Roger Sherman had the comma restored. The altered punctuation, Gallatin said, would have turned "words [that] had originally been inserted in the Constitution as a limitation to the power of levying taxes" into "a distinct power." Thirty years later, Virginia Rep. Mark Alexander accused Secretary of State John Quincy Adams of doing the same thing after Congress instructed the administration to print copies of the Constitution.

The punctuation debate simply reinforced James Madison's point in Federalist No. 41 that Congress could tax and spend only for those objects enumerated, primarily in Article I, Section 8.

Congress enacted very few taxes up to the end of the Civil War, and none that was a pretext for regulating things that the Constitution gave it no power to regulate. True, the purpose of tariffs was to protect domestic industry from foreign competition, not raise revenue. But the Constitution grants Congress a plenary power to regulate commerce with other nations.
Congress also enacted a tax to destroy state bank notes in 1866, but this could be seen as a "necessary and proper" means to stop the states from usurping Congress's monetary or currency power. It was upheld in Veazie Bank v. Fenno (1869).

The first unabashed use of the taxing power for regulatory purposes came when Congress enacted a tax on "oleomargarine" in 1886. Dairy farmers tried to drive this cheaper butter substitute from the market but could only get Congress to adopt a mild tax, based on the claim that margarine was often artificially colored and fraudulently sold as butter. President Grover Cleveland reluctantly signed the bill, saying that if he were convinced the revenue aspect was simply a pretext "to destroy . . . one industry of our people for the protection and benefit of another," he would have vetoed it.
Congress imposed another tax on margarine in 1902, which the Supreme Court upheld (U.S. v. McCray, 1904). Three justices dissented, but without writing an opinion.

Then, in 1914, Congress imposed taxes on druggists' sales of opiates as a way to regulate their use. Five years later, in U.S. v. Doremus , the Supreme Court upheld the levy under Congress's express power to impose excise taxes.
Then, in 1922, the court rejected Congress's attempt to prohibit child labor by imposing a tax on companies that employed children. An earlier attempt to accomplish this, by prohibiting the interstate shipment of goods made by child labor, was struck down as unconstitutional—since it was understood since the earliest days of the republic that Congress had the power to regulate commerce but not manufacturing. "A Court must be blind not to see that the so-called tax is imposed to stop the employment of children within the age limits prescribed," Chief Justice William Howard Taft wrote in Bailey v. Drexel Furniture Co. "Its prohibitory and regulatory effect and purpose are palpable." Even liberal justices Oliver Wendell Holmes and Louis D. Brandeis concurred in Taft's opinion.
Things came to a head in the New Deal, when Congress imposed a tax on food and fiber processors and used those tax dollars to provide benefits to farmers. Though in U.S. v. Butler (1936) the court adopted a more expansive view of the taxing power—allowing Congress to tax and spend for the "general welfare" beyond the powers specifically enumerated in the Constitution—it still held the ends had to be "general" and not transfer payments from one group to another. After President Franklin D. Roosevelt threatened to "pack" the Supreme Court in 1937, it accepted such transfer payments in Mulford v. Smith (1939), so long as the taxes were paid into the general treasury and not earmarked for farmers.
And now, in 2012, Justice Roberts has confirmed that there are no limits to regulatory taxation as long as the revenue is deposited in the U.S. Treasury.
Are there any other limits? Article I, Section 2 says that "direct taxes shall be apportioned among the states" according to population. This is repeated in Article I, Section 9, which says that "no capitation, or other direct tax, shall be laid," unless apportioned.






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Congress convening at the U.S. Capitol
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The Supreme Court struck down income taxes in 1895 (Pollock v. Farmers' Loan & Trust Co.), on the ground that they were "direct" taxes but not apportioned by population. Apportioning an income tax would defeat the purpose of the relatively poorer Southern and Western states, who wanted the relatively richer states of the Northeast to pay the bulk of the tax. The 16th Amendment gave Congress the power to tax incomes without apportionment.
Other direct taxes should presumably have to be apportioned according to the Constitution. Justice Roberts quickly dismissed the notion that the individual mandate penalty-tax is not a direct tax "under this Court's precedents." To any sentient adult, it looks like a "capitation" or head tax, imposed upon individuals directly. Unfortunately, having plenty of other reasons to object to ObamaCare, the four dissenting justices in NFIB v. Sebelius did not explore this point.

Some conservatives have cheered that part of Justice Roberts's decision that limits Congress's Commerce Clause power. But an unlimited taxing power is equally dangerous to constitutional government.

Mr. Moreno is a professor of history at Hillsdale College and the author of "The American State from the Civil War to the New Deal," forthcoming from Cambridge University Press.
A version of this article appeared July 7, 2012, on page A13 in the U.S. edition of The Wall Street Journal, with the headline: A Short History of Congress's Power to Tax.



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America’s Most Biblically-Hostile U. S. President

I received a link to this via email and think it is of sufficient significance to post it in it's entirety.  My question becomes "Just how much malfeasance does the President of the United States have to engage in before Congress stands up and says "This man must be impeached.""?

David Barton

America’s Most Biblically-Hostile U. S. President When one observes President Obama’s unwillingness to accommodate America’s four-century long religious conscience protection through his attempts to require Catholics to go against their own doctrines and beliefs, one is tempted to say that he is anti-Catholic. But that characterization would not be correct. Although he has recently singled out Catholics, he has equally targeted traditional Protestant beliefs over the past four years. So since he has attacked Catholics and Protestants, one is tempted to say that he is anti-Christian. But that, too, would be inaccurate. He has been equally disrespectful in his appalling treatment of religious Jews in general and Israel in particular. So perhaps the most accurate description of his antipathy toward Catholics, Protestants, religious Jews, and the Jewish nation would be to characterize him as anti-Biblical. And then when his hostility toward Biblical people of faith is contrasted with his preferential treatment of Muslims and Muslim nations, it further strengthens the accuracy of the anti-Biblical descriptor. In fact, there have been numerous clearly documented times when his pro-Islam positions have been the cause of his anti-Biblical actions. Listed below in chronological order are (1) numerous records of his attacks on Biblical persons or organizations; (2) examples of the hostility toward Biblical faith that have become evident in the past three years in the Obama-led military; (3) a listing of his open attacks on Biblical values; and finally (4) a listing of numerous incidents of his preferential deference for Islam’s activities and positions, including letting his Islamic advisors guide and influence his hostility toward people of Biblical faith. 1. Acts of hostility toward people of Biblical faith: April 2008 – Obama speaks disrespectfully of Christians, saying they “cling to guns or religion” and have an “antipathy to people who aren't like them.” 1 February 2009 – Obama announces plans to revoke conscience protection for health workers who refuse to participate in medical activities that go against their beliefs, and fully implements the plan in February 2011. 2 April 2009 – When speaking at Georgetown University, Obama orders that a monogram symbolizing Jesus' name be covered when he is making his speech.3 May 2009 – Obama declines to host services for the National Prayer Day (a day established by federal law) at the White House. 4 April 2009 – In a deliberate act of disrespect, Obama nominated three pro-abortion ambassadors to the Vatican; of course, the pro-life Vatican rejected all three. 5 October 19, 2010 – Obama begins deliberately omitting the phrase about “the Creator” when quoting the Declaration of Independence – an omission he has made on no less than seven occasions. 6 November 2010 – Obama misquotes the National Motto, saying it is “E pluribus unum” rather than “In God We Trust” as established by federal law. 7 January 2011 – After a federal law was passed to transfer a WWI Memorial in the Mojave Desert to private ownership, the U. S. Supreme Court ruled that the cross in the memorial could continue to stand, but the Obama administration refused to allow the land to be transferred as required by law, and refused to allow the cross to be re-erected as ordered by the Court. 8 February 2011 – Although he filled posts in the State Department, for more than two years Obama did not fill the post of religious freedom ambassador, an official that works against religious persecution across the world; he filled it only after heavy pressure from the public and from Congress. 9 April 2011 – For the first time in American history, Obama urges passage of a non-discrimination law that does not contain hiring protections for religious groups, forcing religious organizations to hire according to federal mandates without regard to the dictates of their own faith, thus eliminating conscience protection in hiring. 10 August 2011 – The Obama administration releases its new health care rules that override religious conscience protections for medical workers in the areas of abortion and contraception. 11 November 2011 – Obama opposes inclusion of President Franklin Roosevelt’s famous D-Day Prayer in the WWII Memorial. 12 November 2011 – Unlike previous presidents, Obama studiously avoids any religious references in his Thanksgiving speech. 13 December 2011 – The Obama administration denigrates other countries' religious beliefs as an obstacle to radical homosexual rights. 14 January 2012 – The Obama administration argues that the First Amendment provides no protection for churches and synagogues in hiring their pastors and rabbis. 15 February 2012 – The Obama administration forgives student loans in exchange for public service, but announces it will no longer forgive student loans if the public service is related to religion. 16 2. Acts of hostility from the Obama-led military toward people of Biblical faith: June 2011 – The Department of Veterans Affairs forbids references to God and Jesus during burial ceremonies at Houston National Cemetery. 17 August 2011 – The Air Force stops teaching the Just War theory to officers in California because the course is taught by chaplains and is based on a philosophy introduced by St. Augustine in the third century AD – a theory long taught by civilized nations across the world (except America). 18 September 2011 – Air Force Chief of Staff prohibits commanders from notifying airmen of programs and services available to them from chaplains. 19 September 2011 – The Army issues guidelines for Walter Reed Medical Center stipulating that “No religious items (i.e. Bibles, reading materials and/or facts) are allowed to be given away or used during a visit.” 20 November 2011 – The Air Force Academy rescinds support for Operation Christmas Child, a program to send holiday gifts to impoverished children across the world, because the program is run by a Christian charity. 21 November 2011 – The Air Force Academy pays $80,000 to add a Stonehenge-like worship center for pagans, druids, witches and Wiccans. 22 February 2012 – The U. S. Military Academy at West Point disinvites three star Army general and decorated war hero Lieutenant General William G. (“Jerry”) Boykin (retired) from speaking at an event because he is an outspoken Christian. 23 February 2012 – The Air Force removes “God” from the patch of Rapid Capabilities Office (the word on the patch was in Latin: Dei). 24 February 2012 – The Army orders Catholic chaplains not to read a letter to parishioners that their archbishop asked them to read. 25 April 2012 – A checklist for Air Force Inns will no longer include ensuring that a Bible is available in rooms for those who want to use them.26 May 2012 - The Obama administration opposes legislation to protect the rights of conscience for military chaplains who do not wish to perform same-sex marriages in violation of their strongly-held religious beliefs.27 June 2012 - Bibles for the American military have been printed in every conflict since the American Revolution, but the Obama Administration revokes the long-standing U. S. policy of allowing military service emblems to be placed on those military Bibles.28 3. Acts of hostility toward Biblical values: January 2009 – Obama lifts restrictions on U.S. government funding for groups that provide abortion services or counseling abroad, forcing taxpayers to fund pro-abortion groups that either promote or perform abortions in other nations.29 January 2009 – President Obama’s nominee for deputy secretary of state asserts that American taxpayers are required to pay for abortions and that limits on abortion funding are unconstitutional. 30 March 2009 – The Obama administration shut out pro-life groups from attending a White House-sponsored health care summit. 31 March 2009 – Obama orders taxpayer funding of embryonic stem cell research.32 March 2009 – Obama gave $50 million for the UNFPA, the UN population agency that promotes abortion and works closely with Chinese population control officials who use forced abortions and involuntary sterilizations. 33 May 2009 – The White House budget eliminates all funding for abstinence-only education and replaces it with “comprehensive” sexual education, repeatedly proven to increase teen pregnancies and abortions. 34 He continues the deletion in subsequent budgets. 35 May 2009 – Obama officials assemble a terrorism dictionary calling pro-life advocates violent and charging that they use racism in their “criminal” activities. 36 July 2009 – The Obama administration illegally extends federal benefits to same-sex partners of Foreign Service and Executive Branch employees, in direction violation of the federal Defense of Marriage Act. 37 September 16, 2009 – The Obama administration appoints as EEOC Commissioner Chai Feldblum, who asserts that society should “not tolerate” any “private beliefs,” including religious beliefs, if they may negatively affect homosexual “equality.” 38 July 2010 – The Obama administration uses federal funds in violation of federal law to get Kenya to change its constitution to include abortion. 39 August 2010 – The Obama administration Cuts funding for 176 abstinence education programs. 40 September 2010 – The Obama administration tells researchers to ignore a judge’s decision striking down federal funding for embryonic stem cell research.41 February 2011 – Obama directs the Justice Department to stop defending the federal Defense of Marriage Act. 42 March 2011 – The Obama administration refuses to investigate videos showing Planned Parenthood helping alleged sex traffickers get abortions for victimized underage girls. 43 July 2011 – Obama allows homosexuals to serve openly in the military, reversing a policy originally instituted by George Washington in March 1778. 44 September 2011 – The Pentagon directs that military chaplains may perform same-sex marriages at military facilities in violation of the federal Defense of Marriage Act. 45 October 2011 – The Obama administration eliminates federal grants to the U.S. Conference of Catholic Bishops for their extensive programs that aid victims of human trafficking because the Catholic Church is anti-abortion. 46 4. Acts of preferentialism for Islam: May 2009 – While Obama does not host any National Day of Prayer event at the White House, he does host White House Iftar dinners in honor of Ramadan. 47 April 2010 – Christian leader Franklin Graham is disinvited from the Pentagon’s National Day of Prayer Event because of complaints from the Muslim community. 48 April 2010 – The Obama administration requires rewriting of government documents and a change in administration vocabulary to remove terms that are deemed offensive to Muslims, including jihad, jihadists, terrorists, radical Islamic, etc. 49 August 2010 – Obama speaks with great praise of Islam and condescendingly of Christianity. 50 August 2010 – Obama went to great lengths to speak out on multiple occasions on behalf of building an Islamic mosque at Ground Zero, while at the same time he was silent about a Christian church being denied permission to rebuild at that location. 51 2010 – While every White House traditionally issues hundreds of official proclamations and statements on numerous occasions, this White House avoids traditional Biblical holidays and events but regularly recognizes major Muslim holidays, as evidenced by its 2010 statements on Ramadan, Eid-ul-Fitr, Hajj, and Eid-ul-Adha. 52 October 2011 – Obama’s Muslim advisers block Middle Eastern Christians’ access to the White House. 53 February 2012 – The Obama administration makes effulgent apologies for Korans being burned by the U. S. military, 54 but when Bibles were burned by the military, numerous reasons were offered why it was the right thing to do.55 Many of these actions are literally unprecedented – this is the first time they have happened in four centuries of American history. The hostility of President Obama toward Biblical faith and values is without equal from any previous American president. Endnotes 1. Sarah Pulliam Baily, "Obama: ‘They cling to guns or religion’," Christianity Today, April 13, 2008. (Return) 2. Aliza Marcus, "Obama to Lift ‘Conscience’ Rule for Health Workers," Bloomberg, February 27, 2009; Sarah Pulliam Baily, "Obama Admin. Changes Bush ‘Conscience’ Rule for Health Workers," Christianity Today, February 18, 2011. (Return) 3. Jim Lovino, "Jesus Missing From Obama’s Georgetown Speech," NBC Washington, April 17, 2009. (Return) 4. Johanna Neuman, “Obama end Bush-era National Prayer Day Service at White House," Los Angeles Times, May 7, 2009. (Return) 5. Chris McGreal, “Vatican vetoes Barack Obama’s nominees for U.S. Ambassador,”The Guardian, April 14, 2009. (Return) 6. Meredith Jessup, “Obama Continues to Omit ‘Creator’ From Declaration of Independence,” The Blaze, October 19, 2010. (Return) 7. "Remarks by the President at the University of Indonesia in Jakarta, Indonesia,"The White House, November 10, 2010. (Return) 8. LadyImpactOhio, " Feds sued by Veterans to allow stolen Mojave Desert Cross to be rebuilt," Red State, January 14, 2011. (Return) 9. Marrianne Medlin, “Amid criticism, President Obama moves to fill vacant religious ambassador post,” Catholic News Agency, February 9, 2011; Thomas F. Farr, “Undefender of the Faith,” Foreign Policy, April 5, 2012. (Return) 10. Chris Johnson, “ENDA passage effort renewed with Senate introduction,”Washington Blade, April 15, 2011. (Return) 11. Chuck Donovan, “HHS’s New Health Guidelines Trample on Conscience,”Heritage Foundation, August 2, 2011. (Return) 12. Todd Starns, “Obama Administration Opposes FDR Prayer at WWII Memorial,”Fox News, November 4, 2011. (Return) 13. Joel Siegel, “Obama Omits God From Thanksgiving Speech, Riles Critics,” ABC News, November 25, 2011. (Return) 14. Hillary Rodham Clinton, “Remarks in Recognition of International Human Rights Day,” U.S. Department of State, December 6, 2011. (Return) 15. Ted Olson, “Church Wins Firing Case at Supreme Court,” Christianity Today, January 11, 2012. (Return) 16. Audrey Hudson, “Obama administration religious service for student loan forgiveness,” Human Events, February 15, 2012. (Return) 17. “Houston Veterans Claim Censorship of Prayers, Including Ban of ‘God’ and ‘Jesus’,” Fox News, June 29, 2011. (Return) 18. Jason Ukman, “Air Force suspends ethics course that used Bible passages that train missle launch officers,” Washington Post, August 2, 2011. (Return) 19. "Maintaining Government Neutrality Regarding Religion," Department of the Air Force, September 1, 2011. (Return) 20. "Wounded, Ill, and Injured Partners in Care Guidelines," Department of the Navy (accessed on February 29, 2012). (Return) 21. "Air Force Academy Backs Away from Christmas Charity," Fox News Radio, November 4, 2011. (Return) 22. Jenny Dean, "Air Force Academy adapts to pagans, druids, witches and Wiccans," Los Angeles Times, November 26, 2011. (Return) 23. Ken Blackwell, "Gen. Boykin Blocked At West Point," cnsnews.com, February 1, 2012. (Return) 24. Geoff Herbert, " Air Force unit removes 'God' from logo; lawmakers warn of 'dangerous precedent'," syracuse.com, February 9, 2012. (Return) 25. Todd Starnes, "Army Silences Catholic Chaplains," Fox News Radio, February 6, 2012. (Return) 26. Markeshia Ricks, "Bible checklist for Air Force lodges going away," Air Force Times, April 16, 2012. (Return) 27. Patrick Goodenough, "White House 'Strongly Objects' to Legislation Protecting Military Chaplains from Doing Same-Sex Weddings or Being Forced to Act Against Conscience," cnsnews.com, May 16, 2012. (Return) 28. "U.S. military insignia no longer allowed on Bibles," One News Now, June 14, 2012. (Return) 29. Jeff Mason and Deborah Charles, "Obama lifts restrictions on abortion funding,"Reuters, January 23, 2009. (Return) 30. "Obama pick: Taxpayers must fund abortions," World Net Daily, January 27, 2009. (Return) 31. Steven Ertelt, "Pro-Life Groups Left Off Obama’s Health Care Summit List, Abortion Advocates OK," LifeNews, March 5, 2009. (Return) 32. " Obama Signs Order Lifting Restrictions on Stem Cell Research Funding," Fox News, March 9, 2009. (Return) 33. Steven Ertelt, “ Obama Administration Announces $50 Million for Pro-Forced Abortion UNFPA,” LifeNews, March 26, 2009; Steven Ertelt, "President Barack Obama’s Pro-Abortion Record: A Pro-Life Compilation," LifeNews, February 11, 2012.(Return) 34. Steven Ertelt, "Barack Obama’s Federal Budget Eliminates Funding for Abstinence-Only Education," LifeNews, May 8, 2009. (Return) 35. Steven Ertelt, "Obama Budget Funds Sex Ed Over Abstinence on 16-1 Margin,"LifeNews, February 14, 2011. (Return) 36. Steven Ertelt, "Obama Admin Terrorism Dictionary Calls Pro-Life Advocates Violent, Racist," LifeNews, May 5, 2009. (Return) 37. "Memorandum for the Heads of Executive Departments and Agencies," The White House, June 17, 2009. (Return) 38. Matt Cover, "Obama’s EEOC Nominee: Society Should ‘Not Tolerate Private Beliefs’ That ‘Adversely Affect’ Homosexuals," cnsnews.com, January 18, 2010.(Return) 39. Tess Civantos, "White House Spent $23M of Taxpayer Money to Back Kenyan Constitution That Legalizes Abortion, GOP Reps Say," Fox News, July 22, 2010.(Return) 40. Steven Ertelt, "Obama, Congress Cut Funding for 176 Abstinence Programs Despite New Study," LifeNews, August 26, 2010. (Return) 41. Steven Ertelt, "President Barack Obama’s Pro-Abortion Record: A Pro-Life Compilation," LifeNews, February 11, 2012. (Return) 42. Brian Montopoli, "Obama administration will no longer defend DOMA," CBSNews, February 23, 2011. (Return) 43. Steven Ertelt, "Obama Admin Ignores Planned Parenthood Sex Trafficking Videos," LifeNews, March 2, 2011. (Return) 44. Elisabeth Bumiller, "Obama Ends ‘Don’t Ask, Don’t Tell’ Policy," New York Times, July 22, 2011; George Washington, The Writings of George Washington, John C. Fitzpatrick, editor (Washington: U. S. Government Printing Office, 1934), Vol. XI, pp. 83-84, from General Orders at Valley Forge on March 14, 1778. (Return) 45. Luis Martinez, "Will Same Sex Marriages Pose a Dilemma for Military Chaplains?," ABC News, October 12, 2011. (Return) 46. Jerry Markon, "Health, abortion issues split Obama administration and Catholic groups," Washington Post, October 31, 2011. (Return) 47. Barack Obama, “ Remarks by the President at Iftar Dinner,” The White House, September 1, 2009; Kristi Keck, “ Obama tones down National Day of Prayer observance,” CNN, May 6, 2009; Dan Gilgoff, “ The White House on National Day of Prayer: A Proclamation, but No Formal Ceremony,” U.S. News, May 1, 2009. (Return) 48. "Franklin Graham Regrets Army's Decision to Rescind Invite to Pentagon Prayer Service," Fox News, April 22, 2010. (Return) 49. “Obama Bans Islam, Jihad From National Security Strategy Document,” Fox News, April 7, 2010; "Counterterror Adviser Defends Jihad as 'Legitimate Tenet of Islam'," Fox News, May 27, 2010; "'Islamic Radicalism' Nixed From Obama Document," CBSNews, April 7, 2010. (Return) 50. Chuck Norris, “ President Obama: Muslim Missionary? (Part 2),” Townhall.com, August 24, 2010; Chuck Norris, "President Obama: Muslim Missionary?,"Townhall.com, August 17, 2010.(Return) 51. Barack Obama, “Remarks by the President at Iftar Dinner,” The White House, August 13, 2010; "Obama Comes Out in Favor of Allowing Mosque Near Ground Zero," Fox News, August 13, 2010; Pamela Geller, "Islamic Supremacism Trumps Christianity at Ground Zero," American Thinker, July 21, 2011. (Return) 52. "WH Fails to Release Easter Proclamation," Fox Nation, April 25, 2011; "President Obama ignores most holy Christian holiday; AFA calls act intentional,"American Family Association (accessed on February 29, 2012).(Return) 53. "Report: Obama’s Muslim Advisers Block Middle Eastern Christians’ Access to the White House," Big Peace (accessed on February 29, 2012). (Return) 54. Masoud Popalzai and Nick Paton Walsh, “ Obama apologizes to Afghanistan for Quran burning,” CNN, February 23, 2012; "USA/Afghanistan-Islamophobia: Pentagon official apologizes for Quran burning," International Islamic News Agency (accessed on February 29, 2012). (Return) 55. "Military burns unsolicited Bibles sent to Afghanistan," CNN, May 22, 2009.(Return)