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marital residence, a 1994 Cadillac, and a 1989 Ford truck
from joint ownership to Mrs. Vetrano.
OPINION
Petitioners advance two positions in their posttrial
brief. First they contend that “Mr. Vetrano had no
unreported income from BMAP”. Second, they contend that
Mrs. Vetrano is eligible for relief as a so-called innocent
spouse under former section 6013(e) or section 6015. The
issues that we decide in this opinion involve petitioners’
contention that “Mr. Vetrano had no unreported income from
BMAP”.
Two preliminary observations are appropriate. First,
in their posttrial brief petitioners do not contend that
the period of limitations on assessments under section
6501(a) expired before respondent issued either of the
notices of deficiency. The petition asserts that the
period of limitations on assessments under section 6501(a)
had expired with respect to petitioner’s separate 1991 and
1992 returns before the notice of deficiency was issued.
Petitioners did not address this issue in their posttrial
brief, and, thus, we consider it waived or abandoned.
See Bradley v. Commissioner, 100 T.C. 367, 370 (1993)
(“Petitioner has not pursued this line of objection on
brief, and we consider it abandoned.”); Stringer v.
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