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Petitioner initially petitioned this Court for review of
respondent’s determination not to abate interest under section
6404. Petitioner then amended her pleading to include a claim
for relief from joint and several liability. We must determine
whether we have jurisdiction to decide petitioner’s claim as to
joint and several liability.
Background
Petitioner and her husband were investors in a TEFRA
partnership, Oak Co., during the years 1982 and 1984. Oak Co.
was an investor in Bishop Energy Technology Associates, which was
an “Elektra Hemisphere” partnership. This Court’s decision
concerning the partnership items for Bishop Energy Technology
Associates, et al., became final on April 3, 1999. Pursuant to
section 6229(d)(2), respondent had 1 year from the date this
Court’s decision became final to assess any additional tax,
penalties or interest in connection with the partnership items or
affected items. On March 27, 2000, which was within 1 year of
the date the Court’s decision became final, respondent assessed
the additional tax, penalties, and interest against the
Siriannis.
Sometime after the March 27, 2000, assessment, petitioner
and her husband requested an abatement of interest on the
deficiency arising from the partnership. On February 7, 2002,
respondent notified the Siriannis of respondent’s final
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