John G. Goettee, Jr. and Marian Goettee - Page 72




                                       - 72 -                                         
               To take account of respondent’s concessions and the                    
          foregoing,                                                                  


                                             Decision will be entered                 
                                        under Rule 155.26                             















               26  The parties have stipulated as follows:                            
                    The parties agree that the methodology to use in                  
               determining the correct amount of interest for each year in            
               issue is first to calculate the interest that accrues on the           
               balance due (giving effect to all payments, credits, and               
               abatements shown on the transcripts - exhibit 3-J) from the            
               appropriate start date determined by the Court to the date             
               interest was paid for that year with no interest accruing              
               during the waiver periods, agreed abatement periods, such              
               further abatement periods as determined by the Court, and              
               such other periods of no interest accrual determined by the            
               Court at issue in the case.  This accrued interest is then             
               subtracted from the total interest assessed.  If the                   
               difference is a positive number, the difference is an                  
               overassessment of interest which should be abated.  Since              
               the total interest assessed has been paid, such                        
               overassessment will constitute an overpayment which should             
               be refunded to petitioners.                                            
               This stipulation is to be given effect in the Rule 155                 
          computations.                                                               





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