- 22 - never received from exercise of the stock options. The parties dispute the significance of Mr. Chou’s pledge of the Cisco stock to support a loan and use of the proceeds of the loan for purposes other than payment of taxes. On the record in this case, we conclude that the benefit factor neither favors nor precludes relief. With regard to health factors, the briefs authored by petitioners’ counsel repeatedly assert that Mrs. Chou had recently given birth and was caring for a newborn infant. Within the briefs, filed in January and March 2007, the infant is at various places described as born in “late 2000”, newborn, 6 months old, 8 months old, and 9 months old. While thus so careless with the facts on which they rely, the briefs accuse respondent of “inaccuracies” and “shoddy analysis”. These arguments are unsupported, unpersuasive, and inexcusable. The briefs frequently assert “the physical and mental demands on the mother of a newborn infant” as a health issue and as excusing lack of knowledge of the unpaid liability, but nothing in the record supports that characterization. Mrs. Chou testified that her child was born on August 1, 2000, and the return was signed in April 2001. The extent of her testimony with respect to the “demands” of motherhood was as follows: Q [Mrs. Chou’s counsel] Lot of work taking care of an infant? A [Mrs. Chou] Yes, definitely.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: November 10, 2007