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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case, Congress enacted section 6015, and simultaneously repealed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.
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