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reluctant to find that respondent abused her discretion here
when, for all the records show, she was not even timely requested
to exercise it. See Haught v. Commissioner, T.C. Memo. 1993-58;
Lapin v. Commissioner, T.C. Memo. 1990-343, affd. without
published opinion 956 F.2d 1167 (9th Cir. 1992). The records in
these cases do not establish an abuse of discretion on the part
of respondent but support respondent's position. Accordingly, we
hold that respondent's refusal to waive the section 6659
additions to tax is not an abuse of discretion.
Issue 5. Sec. 6621(c) Tax-Motivated Transactions
In notices of deficiency, respondent determined that
interest on deficiencies accruing after December 31, 1984, would
be calculated under section 6621(c). The annual rate of interest
under section 6621(c) equals 120 percent of the interest payable
under section 6601 with respect to any substantial underpayment
attributable to tax-motivated transactions. An underpayment is
substantial if it exceeds $1,000. Sec. 6621(c)(2).
The underlying facts of these cases are substantially the
same as those in Fine v. Commissioner, supra. In addition,
petitioners' arguments on brief with respect to this issue are
verbatim copies of the arguments in the taxpayers' briefs in the
Fine case. For reasons set forth in the Fine opinion, we hold
that respondent's determination as to the applicable interest
rate for deficiencies attributable to tax-motivated transactions
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