- 52 - memorabilia during the years at issue. He made several sales of baseball cards during 1991 and 1992 the gains from which were not reported on petitioners' returns. The fact that he may have used the proceeds to purchase other cards or memorabilia, does not exclude the gain from petitioners' income in the year of the sale. Petitioners have offered no reasonable explanation for their failure to report all the income from Raymond's sports memorabilia activity. Therefore, petitioners are liable for the accuracy-related penalty under section 6662(a). Issue 4. Whether Petitioner Barbara Kling Is Eligible for Relief Under Section 6015 With Respect to Any Understatement of Tax Attributable to the Sports Memorabilia Activity In the petition, Barbara alleged that she was entitled to relief pursuant to section 6013(e). Prior to the trial in this case, Congress enacted section 6015, and simultaneously repealed section 6013(e).7 Section 6015 provides three avenues of relief from joint and several liability: (1) Section 6015(b)(1) (which is similar to former section 6013(e)) allows a spouse to escape completely joint and several liability; (2) section 6015(b)(2) and (c) allow a spouse to elect limited liability through relief from a portion of the understatement or deficiency; and (3) section 6015(f) confers upon the Secretary discretion to grant 7Sec. 6015 generally applies to any liability for tax arising after July 22, 1998, and any liability for tax arising on or before July 22, 1998, that remains unpaid as of such date. See H. Conf. Rept. 105-599, at 251 (1998), 1998-3 C.B. 747, 1005.Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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