- 3 -
determination not to abate the interest. The Siriannis timely
filed a petition for review of respondent’s determination under
the provisions of section 6404.
The petition was filed in the names of Louise Sirianni and
Sam Sirianni (Mr. Sirianni); however, Mr. Sirianni did not sign
the petition. Petitioner informed respondent that Mr. Sirianni
passed away on May 15, 2001. Because a petition was not filed on
behalf of Mr. Sirianni or his estate, respondent moved to dismiss
Mr. Sirianni from the case. We granted respondent’s motion.
On or about October 25, 2002, petitioner submitted an
administrative request to respondent for relief from joint and
several liability under section 6015. On February 6, 2003,
before she received a determination from respondent and less than
6 months after her administrative request, the petition was
amended to include a claim for relief under section 6015. On
February 14, 2003, respondent denied petitioner’s administrative
request, and on March 25, 2003, petitioner filed an
administrative appeal with respondent’s Appeals Office.
Petitioner’s administrative appeal is currently pending
administrative review.
On June 30, 2003, 8 months from the date that petitioner
filed her section 6015 administrative request, respondent moved
for partial summary judgment as to whether petitioner is entitled
to raise a claim for relief under section 6015 in this proceeding
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011