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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.
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