- 26 - offering memorandum warned that the Internal Revenue Service would likely challenge their purported value. Yet the record indicates that petitioners' sought no verification of the value of the recyclers; their only concern was whether the recyclers actually existed. Petitioners did not have a reasonable basis for the adjusted bases or valuations claimed on their 1981 returns with respect to their investments in Hyannis. Accordingly, in these cases respondent could find that petitioners' purported reliance on Greenstein and the promotional materials was unreasonable. The records here do not establish an abuse of discretion on the part of respondent but support respondent's position. We hold that respondent's refusal to waive the section 6659 additions to tax is not an abuse of discretion. Petitioners are liable for the respective section 6659 additions 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. Issue 3. Sec. 6621(c) Tax-Motivated Transactions With respect to petitioners Pace, respondent determined that interest on deficiencies accruing after December 31, 1984, would be calculated under section 6621(c). Petitioners Pace have the burden of proving that respondent's determination is erroneous. Rule 142(a); Luman v. Commissioner, 79 T.C. 846 (1982). With respect to petitioners Berry, respondent asserted the section 6621(c) interest calculation in an amendment to answer. BecausePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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