Michael Vetrano and Patricia Vetrano - Page 8




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             had not established her eligibility to elect relief under                
             section 6015(c) because she had not established either that              
             she was no longer married to, or was legally separated                   
             from, Mr. Vetrano at the time she elected under section                  
             6015(c), nor had she established that she was not a member               
             of the same household at any time during the 12-month                    
             period ending on the date she made her election under                    
             section 6015(c).  See sec. 6015(c)(3)(A)(i).  Respondent                 
             also repeated the arguments that Mrs. Vetrano's election                 
             under section 6015(c) does not apply to any part of the                  
             deficiency because Mrs. Vetrano had actual knowledge of                  
             all of the items giving rise to the deficiency, see sec.                 
             6015(c)(3)(C), that her share of the deficiency should be                
             increased by the value of certain "disqualified assets"                  
             that Mr. Vetrano transferred to her, sec. 6015(c)(4)(A),                 
             and that Mrs. Vetrano should remain jointly and severally                
             liable for the deficiency at issue because of her fraud,                 
             see sec. 6015(d)(3)(C).  Respondent did not repeat the                   
             argument that Mrs. Vetrano is ineligible to elect relief                 
             under section 6015(c) because assets were transferred to                 
             her by her husband as part of a fraudulent scheme.  See                  
             sec. 6015(c)(3)(A)(ii).                                                  
                 Thereafter, the Court issued an order giving the                    
             parties 30 days in which to request further trial in this                






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