Michael Vetrano and Patricia Vetrano - Page 3




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             automobile parts business, that the returns at issue are                 
             subject to the fraud penalty under section 6663, and that                
             some part of the underpayment for 1993 is due to the fraud               
             of Mrs. Vetrano.  We also sustained respondent's                         
             determination that petitioners had received unreported                   
             payments from four entities during the years in issue,                   
             including a payment of $1,035 from Camden City Probation                 
             in 1993.                                                                 
                  In Vetrano I, we did not consider Mrs. Vetrano's                    
             claim for relief from joint and several liability under                  
             former section 6013(e) and section 6015 of the Internal                  
             Revenue Code.  We reserved those issues in order to give                 
             Mrs. Vetrano an opportunity to make a record to support her              
             claim of eligibility for relief under section 6015, in view              
             of the fact that section 6015 was enacted after the trial                
             of this case.  See Internal Revenue Service Restructuring                
             and Reform Act of 1998, Pub. L. 105-206, sec. 3201(a), 112               
             Stat. 734 (hereinafter the Act is referred to as RRA 1998).              
             Unless stated otherwise in this opinion, all section                     
             references, other than references to section 6015, are                   
             references to the Internal Revenue Code as in effect during              
             1993.                                                                    
                  We must now decide three issues in order to complete                
             our opinion in this case.  The first issue is whether to                 






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