John G. Goettee, Jr. and Marian Goettee - Page 52




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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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