Lately I have received questions how it is that Willie Nelson lost most of his property and Wesley Snipes was sentenced to three years in jail or Irwin Schiff was sentenced to 13 years in prison from charges relating to income tax. I have repeatedly held that it is because people who are brought into tax court do not challenge jurisdiction by filing a counterclaim in a court of record and have thought that should be enough information to satisfy the questioner.
The judgment of a court of record whose jurisdiction is final is as conclusive on all the world as the judgment of this court would be. It is as conclusive on this court as it is on other courts. It puts an end to inquiry concerning the fact by deciding it.
Ex parte Watkins, 3 Pet., at 202-203. [cited by SCHNECKLOTH v. BUSTAMONTE, 412 U.S. 218, 255 (1973)]