Louise Sirianni - Page 2

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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.                                                
               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                     
               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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