Kent J. and Ruth W. Dawson - Page 19

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          adjusted basis or valuations claimed on the returns and that such           
          claims were made in good faith.  Respondent's refusal to waive a            
          section 6659 addition to tax is reviewable by this Court for                
          abuse of discretion.  Krause v. Commissioner, 99 T.C. at 179.               
               Petitioner argues that he arrived at his valuation of the              
          tapes by virtue of his relying on Geldbach and Andrews, and on an           
          appraisal prepared by McGraw-Hill, in addition to representations           
          made in the offering materials.  He contends that such reliance             
          was reasonable, and, therefore, respondent should have waived the           
          section 6659 addition to tax.  We have found that petitioner's              
          reliance on the above was not reasonable because neither Geldbach           
          nor Andrews had expertise in continuing medical education, the              
          offering materials contained numerous disclaimers and stated that           
          prior similar ventures had not been as successful as predicted,             
          and petitioner did not perform any independent investigation into           
          the history, experience, credibility, reputation, or finances of            
          MSA or its promoters.                                                       
               Petitioners did not have a reasonable basis for the adjusted           
          base or valuation claimed on their 1983 return with respect to              
          their investment in MSA.   The record does not establish an abuse           
          of discretion on the part of respondent with respect to the                 
          addition to tax under section 6659.  In addition, the record                
          fails to indicate that petitioners ever requested a waiver from             
          respondent pursuant to section 6659(e) until briefing after                 






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