No, not the 1960 Jules Dassin-Melina Mercouri film that gave rise to that year’s Oscar-winning tune, but rather the sad tale of Sunday G. Agwu, caught up in the toils of Tax Court and the IRS.

You’ll find the whole shebang in Docket No. 12997-12S, and Judge Buch tells the tale. You can learn more about Judge Buch from my blogpost “An Open Buch”, 1/16/13.

Anyway, here’s the mise-en-scène:  “…respondent [IRS] submìtted to the Court, prior to the call of the calendar, a stipulated decision that had been signed both by petitioner (Mr. Agwu) and on behalf of respondent.

“A few hours after the call of the calendar (and after the Court had initially concluded for the day), petitioner arrived at Court and began an off-the-record conversation with respondent’s counsel. Because of the apparent disagreement between the parties, the Court intervened and held an off-the-record conference with the parties. The Court then went on the record to describe the issues and confirm with the parties that the Court was accurately describing the apparent dispute.

“Petitioner stated that he was misled into signing a stipulated decision. He understood that, if he signed the stipulated decision, the IRS would not pursue collection activity against him.” Order, p. 1.

Nice work if you can get it, Sunny, but not quite.

“Respondent’s counsel stated that she advised petitioner that he could work with the IRS to address collection alternatives, including an offer in compromise, an installment agreement, or being placed in currently not collectible status.” Order, p. 1.

Now whether Sunny understood Word One of the foregoing is a good question. Ya gotta wonder how the self-representeds fare in a Court where even seasoned litigators often come seriously unglued. I’ve blogged this so often I won’t even cite to my past blogs. The “People’s Court” is a minefield that makes Afghanistan look like a kindergarten playground.

So Judge Buch catechizes Sunny, tells him this is liability and not collection, and elicits the following: “In this regard, Mr. Agwu stated that he does not dispute the terms of the stipulated decision. Indeed, he agrees that the 2006 and 2008 tax deficiencies shown in the stipulated decision document are correct; he agrees that he did not file tax returns for 2006 and 2008; and he agrees that he did not pay his taxes for 2006 and 2008. These oral concessions conform to the terms of the stipulated decision and also conform to the notices of deficiency on which this case is based.” Order, p. 1.

Sunny’s story is “I ain’t got no money, honey.”

Sunny having thus offered himself up as a living sacrifice, Judge Buch files the stipulated decision, and directs Sunny to file “…a response to this Order in which he explains (shows cause) why his case should not be dismissed for failure to state a claim upon which relief can be granted.” Order, p. 2.

And the best of luck, Sunny. Did you understand Word One of the foregoing?