BankAmerica Corporation, as successor in interest to Continental Bank Corporation, as successor in interest to Continental Illinois Corporation - Page 16

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          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,              




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