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In 1990 petitioner pleaded no contest to two felony charges
of attempted child pandering and was sentenced to 1 year in jail
with credit for time served and suspension of the balance of the
sentence and probation. Since his conviction, petitioner has
encountered difficulties securing a job meeting his financial
expectations.
Petitioner did not file a Federal income tax return for
1997. During 1997 petitioner received wages of $1,680,
nonemployee compensation of $10,201, prizes and awards of
$33,720, interest of $62, and a distribution of $1,000 from an
IRA. These amounts total $46,663 as determined by respondent in
the notice of deficiency.
Petitioner contends: (1) No provision of law makes him
liable for Federal income tax; and (2) he is not liable for
Federal income tax for 1997 because the Federal Government
allegedly owes him compensation for violating his rights in
connection with certain felony charges in 1990.
The facts in this case have been established by written and
oral stipulation, and there are no material facts in dispute.
Since only legal issues remain, the burden of proof with respect
to the deficiency is irrelevant. Nis Family Trust v.
Commissioner, 115 T.C. 523, 538 (2000).
Petitioner’s first argument, that no provision of law makes
him liable for Federal income tax, is frivolous. Section 61(a)
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