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(c), I.R.C., and chose not to present any
additional evidence regarding those issues.
R contends that W should not be permitted to
withdraw, without prejudice, her elections under
sec. 6015(b) and (c), I.R.C., and that W is not
entitled to relief under either of those
provisions.
1. Held: W's request to withdraw, without
prejudice, the issue of her qualification for
relief under subsections (b) and (c) of sec.
6015, I.R.C., is denied. W placed those matters
in issue in this case. Sec. 6015(g)(2), I.R.C.,
prescribes the res judicata effect that a final
decision in this case will have with respect to a
later election by W under sec. 6015, I.R.C., and
precludes granting W's request to withdraw her
elections without prejudice.
2. Held, further, W does not qualify for
relief under subsection (b) of sec. 6015, I.R.C.,
nor has she shown that she meets the requirements
of sec. 6015(c)(3)(A)(i), I.R.C., in order to be
entitled to elect relief under sec. 6015(c),
I.R.C.
John R. Crayton, for petitioners.
Keith L. Gorman and John E. Becker, Jr., for
respondent.
SUPPLEMENTAL OPINION
WHALEN, Judge: Our Memorandum Findings of Fact and
Opinion of this case was issued as T.C. Memo. 2000-128
on April 10, 2000 (Vetrano I). In that opinion, we found
that Mr. Vetrano had earned unreported net income in 1991,
1992, and 1993, from his business of dealing in used
automobile parts, consisting primarily of payments from a
company referred to as BMAP, that he is subject to self-
employment tax on the unreported net income of his used
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