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affd. 859 F.2d 115 (9th Cir. 1988). However, section 7481(c)
specifically carves out an exception to the rule on the finality
of our decisions. Indeed, a prerequisite for invoking section
7481(c) is that the decision be final. Aldrich v. Commissioner,
T.C. Memo. 1993-290. Thus, as long as we do not change the
substance of the final decision, we are free to act under section
7481(c).
Stauffacher v. Commissioner, supra, cited by respondent, is
clearly distinguishable. In that case, the taxpayer sought a
change in the amount of deficiencies, although the taxpayer was
apparently requesting that this be done only for the purpose of
computing interest. Petitioner herein is not seeking a change in
the amounts of the deficiencies for any purpose. We do not think
that the fact that the 1994 decision specifically incorporated
the 1994 computations, see supra p. 4, requires a different
conclusion. Under the circumstances herein, such action does not
elevate the computations from a position of providing a basis for
the decision to the position of an integral part of the decision
itself.
Respondent also seeks refuge in the rule that petitioner may
not raise a new issue in a Rule 155 proceeding. Cloes v.
Commissioner, 79 T.C. 933 (1982). But even if the issue of the
proper application of the 1979 ITC as it affects interest
liability were never raised before, it is not a "new issue"
within the meaning of Rule 155. Since in the instant case the
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