John G. Goette, Jr. and Marian Goettee - Page 1

                                   124 T.C. No. 17                                    

                               UNITED STATES TAX COURT                                

              JOHN G. GOETTEE, JR. AND MARIAN GOETTEE, Petitioners v.                 
                   COMMISSIONER OF INTERNAL REVENUE, Respondent*                      

              Docket No. 26591-96.              Filed May 31, 2005.                   

                   Ps claimed investment credits and losses arising out of            
              a partnership in which they held a limited interest.  By                
              notice of deficiency, R disallowed these claimed credits and            
              losses.  Ps accepted a settlement offer from R and paid all             
              deficiencies and additions reflected in the entered                     
              decision.  Ps requested abatement of interest on these                  
              amounts.  R initially disallowed the abatement request in               
              full, then later allowed partial abatement.  Ps then paid               
              the remaining assessed interest liabilities.  Ps petitioned             
              this Court to review R’s disallowance of interest                       
              abatements.  After R’s concessions, we determined (1) R                 
              abused R’s discretion only for the period Jan. 24 through               
              Apr. 24, 1995, and not for any of the other time periods                
              (aggregating about 15-3/4 months) specifically put in issue,            

               * This opinion supplements our previously filed opinions in            
          Goettee v. Commissioner, T.C. Memo. 1997-454, T.C. Memo. 2003-43            
          (hereinafter sometimes referred to as Goettee I), and T.C. Memo.            

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