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reach the result desired by the moving party. See Estate of
Quick v. Commissioner, 110 T.C. at 441-442; Stoody v.
Commissioner, 67 T.C. 643, 644 (1977). In the instant case,
petitioners have not presented such newly discovered evidence and
have not shown such unusual circumstances or substantial error.
We discuss seriatim petitioners’ requests.
1. Erroneous calculations.
Respondent acknowledged, and we found, that respondent
overassessed interest in at least the amounts of $108.33 for 1981
and $298.47 for 1982. We directed the parties in note 26 of the
Opinion, pursuant to the parties’ stipulation, to correct these
errors and any other calculation errors by recalculating the
amounts of interest for each year in issue. Accordingly, this
issue is already dealt with, and properly dealt with, in Goettee
I and will not be reconsidered.
2. Sept. 9 through Oct. 3, 1995; Sept. 21 through Nov. 13,
1996.
Petitioners did not ask us to consider at trial or on brief
the specific time periods set forth in their motion that were
allegedly confused or ignored by the Commissioner’s Appeals
Office during which errors or delays occurred that warrant
abatement of interest. Instead, petitioners asked the Court, on
answering brief, to order an abatement for additional unspecified
time periods. In Goettee I we declined to do so. We do not now
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