The taxpayer was a former assistant U.S. attorney who suffered from various health ailments, including cardiac disorders, depression, and memory loss. He retired in 2000 because of disability. For 2007, the year at issue, he prepared his own tax return. He claimed that distributions from an IRA were a return of investments made through nondeductible contributions, and that the gains on those investments should be taxed as capital gains rather than ordinary income. The taxpayer produced no evidence to support his claim that the IRA contributions were made with after-tax funds. Nor could he cite any law to support his claim that the gain on his non-deductible contributions should be taxed as capital gains rather than ordinary income. The Court ruled all of the IRA distributions were taxable as ordinary income.