Jeffrey Chou and Cindy Chou - Page 14




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                                       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.                                                                       








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