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these cases respondent properly could find that petitioners'
reliance on Tomasetti, Frabotta, and Omohundro, in addition to
the offering materials, was unreasonable. The records in these
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. Petitioners are liable for the
section 6659 addition to tax at the rate of 30 percent of the
underpayment of tax attributable to the disallowed tax benefits.
Respondent is sustained on this issue.
Decisions will be entered
under Rule 155.
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