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case with respect to Mrs. Vetrano's eligibility for relief
under section 6015. In that order, the Court noted that if
further trial were not held, pursuant to the request of the
parties, then the case would remain submitted on the basis
of the existing record. Petitioners filed no report in
response to the Court's order and, thus, did not request
further trial.
Respondent's response to the Court's order "requests
that further trial be held as to Patricia Vetrano's
qualification to claim relief under �6015(c), the value of
assets transferred to her under �6015(c)(4), and any other
facts the Court may need to make a decision on the merits."
Respondent also makes the following concession:
In addition, respondent now understands that
petitioners were divorced on February 2, 1999
and, to save time, respondent would now concede
that she is now divorced and she is entitled to
make a claim under I.R.C. �6015(c)(3)(A)(i).
Discussion
At the outset, we note that former section 6013(e)
was stricken from the Internal Revenue Code upon the
passage of section 6015. See RRA 1998 sec. 3201(e)(1), 112
Stat. 740. This change applies to any tax liability which
arose after the date of enactment of RRA 1998; i.e., July
22, 1998, or any tax liability which arose before such date
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