John H. Webster - Page 4

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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               
               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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