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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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