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Snyder will not be relieved of the section 6659 additions to tax
based on the preliminary reports prepared by Carmagnola.
We hold that Snyder did not have a reasonable basis for the
adjusted bases or valuations reflected on his returns with
respect to his investments in the Partnerships. Respondent
properly could find herein that Snyder's reliance on the offering
materials, Becker, and Miller was unreasonable. The records in
Snyder's cases 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 addition to
tax is not an abuse of discretion. Respondent is sustained on
this issue.
Decisions will be entered
under Rule 155.
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