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respondent was correct in finding that petitioner's reliance on
the appraisal in the promotional materials was unreasonable. The
record in this case does not establish an abuse of discretion on
the part of respondent but supports respondent's position. We
hold that respondent's refusal to waive the section 6659 addition
to tax is not an abuse of discretion. Petitioners are liable for
the section 6659 addition to tax at the rate of 30 percent of the
underpayment of tax attributable to the disallowed credits for
1981. Respondent is sustained on this issue.
Decision will be entered
under Rule 155.
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