- 14 - OPINION This is an unusual case, in which petitioners insist that we should reject respondent’s concession that they owe no tax liability for 2001, that the assessment based on petitioners’ amended return for that year will be abated, and that no collection action will be taken with respect to that assessment. Petitioners ask the Court to determine that they owe tax of $578,052 for 2001. Petitioners’ obvious purpose is to have the Court determine that they do not owe the tax that they originally reported for 2000, a question that is not properly before the Court in this case. The parties were able to cooperate with respect to a fairly complete stipulation, but not otherwise. Petitioners’ rhetoric includes irresponsible accusations against respondent, and respondent unnecessarily attacks the credibility of petitioners’ testimony, even after the Court commented at trial that their testimony was credible. We do not condone or address at length such overzealous advocacy and meritless arguments. Lack of objectivity serves no purpose other than unreasonably to protract these proceedings. For the reasons set forth below, we conclude that there is only one issue properly before the Court, and that is Mrs. Chou’s entitlement to relief under section 6015(f) for 2000.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: November 10, 2007