Warren G. Buck and Judith A. Buck - Page 19

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          in their 1983 return with respect to Ridge Energy.  On the record           
          before us, we further find that, assuming arguendo that petition-           
          ers sought a waiver under section 6661(c), they have not estab-             
          lished that respondent abused her discretion in not granting any            
          such request.                                                               
               Based on the entire record before us, we find that petition-           
          ers have failed to satisfy their burden of proving that for 1983            
          they had substantial authority for claiming in their 1983 return            
          the loss of $13,919 and the investment tax credit of $20,899 with           
          respect to Ridge Energy, that that return position was more                 
          likely than not the proper treatment, and that, assuming arguendo           
          that petitioners requested a waiver under section 6661(c),                  
          respondent abused her discretion in not granting any such re-               
          quest.  Accordingly, we sustain respondent's determination                  
          imposing for 1983 the addition to tax under section 6661(a).                
               To reflect the foregoing,                                              


                                             Decision will be entered for             
                                        respondent.                                   














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