John G. Goettee, Jr. and Marian Goettee - Page 4

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               After concessions by both sides,2 there are two categories             
          of issues for decision, as follows:                                         
                    (1)  Whether respondent’s failure to abate interest for           
               certain time periods constitutes an abuse of discretion.               
                    (2)  Whether respondent’s interest computations are               
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated; the stipulations and           
          the stipulated exhibits are incorporated herein by this                     
               When the petition was filed in the instant case,                       
          petitioners, John G. Goettee, Jr. (hereinafter sometimes referred           
          to as John), and Marian Goettee (hereinafter sometimes referred             

               2  As noted supra, petitioners concede as to interest on               
          underpayments for 1983.                                                     
               Respondent concedes that respondent underabated the amount             
          of interest for the period Oct. 4, 1995, through Sept. 20, 1996.            
               The parties agree that there remain overassessments for 1981           
          and 1982.  Respondent contends that insufficient interest was               
          assessed as to underpayments for 1979, but concedes that no                 
          additional amounts of interest are to be assessed against                   
               Other concessions are discussed infra in connection with the           
          issues to which the specific concessions relate.                            
               Respondent concedes that a Rule 155 computation will be                
               Unless indicated otherwise, all Rule References are to the             
          Tax Court Rules of Practice and Procedure.                                  

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