John G. Goettee, Jr. and Marian Goettee - Page 7

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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.             
              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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