- 2 - 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 finalPage: Previous 1 2 3 4 5 6 7 Next
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