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claimed on the returns and that such claims were made in good
faith. The Commissioner'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. Abuse of
discretion has been found in situations where the Commissioner's
refusal to exercise her discretion is arbitrary, capricious, or
unreasonable. See Mailman v. Commissioner, 91 T.C. 1079 (1988);
Estate of Gardner v. Commissioner, 82 T.C. 989 (1984); Haught v.
Commissioner, T.C. Memo. 1993-58.
We note initially that petitioners did not request
respondent to waive the section 6659 additions to tax until well
after the trial of these consolidated cases. Petitioners made
their request more than 6 months after the trial of these
consolidated cases. We are reluctant to find that respondent
abused her discretion in these consolidated cases when she was
not timely requested to exercise it and there is no direct
evidence of any abuse of administrative discretion. Haught v.
Commissioner, supra; cf. Wynn v. Commissioner, T.C. Memo. 1995-
609; Klieger v. Commissioner, T.C. Memo. 1992-734.
However, we do not decide this issue solely on petitioners'
failure timely to request waivers, but instead, we have
considered the issue on its merits. Petitioners urge that they
relied on the respective offering materials and Tucker in
deciding on the valuation claimed on their tax returns.
Petitioners contend that such reliance was reasonable and,
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