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election under section 6015(c) and place the issue of her
eligibility for relief under section 6015(c) before the
Court in these proceedings. We have given her ample
opportunity to do that. However, the election under
section 6015(c) is Mrs. Vetrano's to make, and she has made
it clear that she does not seek to make a second election.
See sec. 6015(a)(2). We suspect that Mrs. Vetrano did not
make a second election because there would be little to
gain from a second election. In Vetrano I, we found that
some part of the underpayment for 1993 was due to
Mrs. Vetrano's fraud based on the fact that "she was aware
of the payments received from BMAP during 1993, and she
played an important part in converting the checks received
from BMAP to cash." Were we to reach the merits of
Mrs. Vetrano's election under section 6015(c), we, no
doubt, would find her election invalid as to the payments
from BMAP because she had "actual knowledge" of those
payments. See sec. 6015(c)(3)(C). Having failed to make a
second election during these proceedings, if Mrs. Vetrano
attempts to make an election under section 6015(c) after
the decision in this case becomes final, then
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