John G. Goettee, Jr. and Marian Goettee - Page 9

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         reach the result desired by the moving party.  See Estate of                 
         Quick v. Commissioner, 110 T.C. at 441-442; Stoody v.                        
         Commissioner, 67 T.C. 643, 644 (1977).  In the instant case,                 
         petitioners have not presented such newly discovered evidence and            
         have not shown such unusual circumstances or substantial error.              
              We discuss seriatim petitioners’ requests.                              
              1.  Erroneous calculations.                                             
              Respondent acknowledged, and we found, that respondent                  
         overassessed interest in at least the amounts of $108.33 for 1981            
         and $298.47 for 1982.  We directed the parties in note 26 of the             
         Opinion, pursuant to the parties’ stipulation, to correct these              
         errors and any other calculation errors by recalculating the                 
         amounts of interest for each year in issue.  Accordingly, this               
         issue is already dealt with, and properly dealt with, in Goettee             
         I and will not be reconsidered.                                              
              2.  Sept. 9 through Oct. 3, 1995; Sept. 21 through Nov. 13,             
              Petitioners did not ask us to consider at trial or on brief             
         the specific time periods set forth in their motion that were                
         allegedly confused or ignored by the Commissioner’s Appeals                  
         Office during which errors or delays occurred that warrant                   
         abatement of interest.  Instead, petitioners asked the Court, on             
         answering brief, to order an abatement for additional unspecified            
         time periods.  In Goettee I we declined to do so.  We do not now             

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