VETRANO v. COMMISSIONER OF INTERNAL REVENUE
United States Tax Court
In the petition, petitioners alleged that wife, W, was entitled to relief from joint and several liability under former sec. 6013(e), I.R.C., with respect to their joint return for 1993. After trial, sec. 6015, I.R.C., was enacted into law and former sec. 6013(e), I.R.C., was repealed. W elected relief under subsections (b) and (c) of sec. 6015, I.R.C., in petitioners' posttrial brief.
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In the petition, petitioners alleged that wife, W, was entitled to relief from joint and several liability under former sec. 6013(e), I.R.C., with respect to their joint return for 1993. After trial, sec. 6015, I.R.C., was enacted into law and former sec. 6013(e), I.R.C., was repealed. W elected relief under subsections (b) and (c) of sec. 6015, I.R.C., in petitioners' posttrial brief. Thereafter, the Court issued its first opinion which decided all of the other issues in the case but reserved W's qualification for relief from joint and several liability in order to give W an opportunity to…
1Opinion of the Court
SUPPLEMENTAL OPINION
Whalen, Judge:
Our Memorandum Findings of Fact and Opinion of this case was issued as T.C. Memo. 2000-128 on April 10, 2000 (Vetrano I). In that opinion, we found that Mr. Vetrano had earned unreported net income in 1991, 1992, and 1993, from his business of dealing in used automobile parts, consisting primarily of payments from a company referred to as BMAP, that he is subject to self-employment tax on the unreported net income of his used automobile parts business, that the returns at issue are subject to the fraud penalty under section 6663, and that some part of the…
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