- 16 - will, if necessary, accept new facts, specifically in the context of a final decision, for the purpose of redetermining interest. Additionally, respondent has never contested the existence of the amounts of ITC, nor has respondent disputed the accuracy of the amounts set forth in petitioner's motion. The record herein contains all the evidence needed to decide the ultimate issue before us. Thus, respondent's assertion of the need for new facts is unfounded. As we view the situation in respect of the procedural elements involved herein, petitioner is simply seeking to flesh out the 1994 computations so as to provide the foundation for a proper calculation of its liability for interest without in any way changing its liabilities for the deficiencies. Although petitioner's efforts reflect changes in some of the numbers in the 1994 computations, those changes do no more than offset each other. This is clearly reflected in the appendix to this opinion which shows that in each year petitioner first adds in the 1979 ITC credits and then subtracts an identical amount. In view of the foregoing, we are satisfied that neither the rule as to the finality of our decisions nor the principle that a new issue may not be raised in a Rule 155 proceeding precludes us from addressing the substance of petitioner's motion. Respondent also objects to any change in the 1994 computations, on the grounds that the computations were based on a stipulation of settlement between petitioner and respondent,Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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