- 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 proceedingPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011