116 T.C. No. 21
UNITED STATES TAX COURT
MICHAEL VETRANO AND PATRICIA VETRANO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 8996-97. Filed April 25, 2001.
In the petition, petitioners alleged that
wife, W, was entitled to relief from joint and
several liability under former sec. 6013(e),
I.R.C., with respect to their joint return for
1993. After trial, sec. 6015, I.R.C., was
enacted into law and former sec. 6013(e), I.R.C.,
was repealed. W elected relief under subsections
(b) and (c) of sec. 6015, I.R.C., in petitioners'
posttrial brief. Thereafter, the Court issued
its first opinion which decided all of the other
issues in the case but reserved W's qualification
for relief from joint and several liability in
order to give W an opportunity to make a record
to support her elections under subsections (b)
and (c) of sec. 6015, I.R.C. Subsequently, W
requested leave to withdraw, without prejudice,
her elections for relief under sec. 6015(b) and
*This opinion supplements our opinion in Vetrano v.
Commissioner, T.C. Memo. 2000-128.
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