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Winkler signed petitioners’ decision document on April 25,
1995, and then forwarded it to the Court for entry of decision.
On May 2, 1995, the Court entered decision in petitioners’ case.
OPINION
Petitioners urge us to grant their amended motion for
reconsideration of our opinion in Goettee I in order to correct
what they contend are the following errors: (1) Goettee I failed
to address respondent’s error in computing the amount of interest
due from petitioners; (2) the Commissioner’s Appeals Office
ignored or confused specific time periods (September 9 through
October 3, 1995, and September 21 through November 13, 1996) for
which interest should have been abated; (3) respondent abused
respondent’s discretion by failing to abate interest that accrued
from December 2, 1993, through October 26, 1994; (4) respondent’s
delay in assessing the liabilities warrants additional abatement
periods; and (5) the Court should give full effect to
respondent’s concession that interest should be abated for April
25, 1995.
Respondent contends that petitioners have not presented
evidence of unusual circumstances or substantial error that would
warrant the granting of a motion for reconsideration. Respondent
argues that (1) respondent did not err in computing the amount of
interest due, but rather, underabated interest for the conceded
abatement periods; (2) petitioners’ request for additional time
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