- 10 - but which remained unpaid as of such date. See RRA 1998 sec. 3201(g)(1), 112 Stat. 740. Following passage of section 6015, petitioners could no longer seek relief from joint and several liability for Mrs. Vetrano with respect to their joint return for 1993 under former section 6013(e). See King v. Commissioner, 115 T.C. 118, 121 (2000); Butler v. Commissioner, 114 T.C. 276, 282 (2000); cf. Miller v. Commissioner, 115 T.C. 582 (2000). As mentioned above, Mrs. Vetrano elected relief under section 6015 in petitioners' posttrial brief. Petitioners' entire argument regarding Mrs. Vetrano's eligibility for relief under section 6015 is as follows: Should this Court determine that Mr. Vetrano received the income from BMAP in 1993 and that Mrs. Vetrano is not entitled to the protection afforded to her under 26 U.S.C. � 6013(e), Mrs. Vetrano hereby elects relief from the joint liability on the 1993 return under 26 U.S.C. � 6015. A copy of that provision is attached as Exhibit "A". Pursuant to � 6015(c)(3)(A)(i)(I), Mrs. Vetrano is "legally separated from" Mr. Vetrano. Attached as Exhibit "B" is a copy of the divorce complaint which was filed against her husband in the Camden County Superior Court on August 7, 1998. [Emphasis supplied.] Petitioners did not seek to formally amend their petition to include relief under section 6015 as an issue in this case, but the parties and the Court have treated it as having been placed at issue. In these circumstances, wePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011