Judge Rose E. (“Cracklin'”) Jenkins directs Angela Stern to file a “protective” Form 8857 Request for Innocent Spouse Relief, with all documentation supporting her claim for relief under I.R.C. § 6015. For the rest, Michael Stern & Angela Stern, Docket No. 11100-23, filed 10/17/2, want either summary J and a one-day trial, or not and a two-day trial. Oh yes, and dismiss Angela for want of jurisdiction, and while you’re at it, Judge, reconsider and cabin the caselaw. There’s more, but that will do for these purposes.

Such a procedural smorgasbord could only have been prepared by The Great Chieftain of the Jersey Boys. Judge Jenkins kicks the case off the November trial calendar and tells the parties to stipulate whatever they can and work out a scheduling order.

But the “protective” filing and concomitant evidentiary proffer raise the conflict question. Can the present counsel lineup remain? Judge Jenkins orders the “protective” filing after a phonathon, so clearly this wasn’t sought at the outset.

The docket shows the Great Chieftain only made a limited appearance. Does conflict of interest arise from the protective filing, as clearly the petitioners’ interests do not mesh? And how far does the conflict extend? Are separate counsel required henceforward for everything?