Louise Sirianni - Page 3

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          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           

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Last modified: May 25, 2011