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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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Last modified: November 10, 2007