- 7 - 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 timePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011