Michael Vetrano and Patricia Vetrano - Page 1

                                   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                  was repealed.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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