- 52 - evidently preferring that we conduct a detailed search. We decline to do so. We hold for respondent on this issue. D. Abatement Periods--Summary We hold for petitioners that respondent’s failure to abate interest for the period January 25 through April 24, 1995, was an abuse of discretion and will order abatement for this period. We hold for respondent as to all other periods placed in dispute in the instant case. II. Interest Computations Respondent twice computed petitioners’ interest liability: once before the August 18, 1995, assessment and once before trial. Petitioners contend that both of respondent’s interest computations contain numerous errors, and that respondent’s failure to correct such errors constitutes an abuse of discretion. Respondent contends that, after taking respondent’s concessions into account, respondent’s trial computations are correct.16 Before reaching the merits of these disputes, we pause to discuss our jurisdiction to correct respondent’s computations. 16 Petitioners point out that, if we were to agree with any of their contentions, then the “bottom line” would take into account the effect of compounding interest on the interest that we would have concluded should not have been assessed. E.g., RJR Nabisco, Inc. v. United States, 955 F.2d 1457 (11th Cir. 1992). Thus, in general the amounts at stake are greater than the amounts formally in dispute.Page: Previous 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 Next
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