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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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