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 After trial, sec. 6015, I.R.C., was enacted into law and former sec. 6013(e), I.R.C., was repealed.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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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