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in their 1983 return with respect to Ridge Energy. On the record
before us, we further find that, assuming arguendo that petition-
ers sought a waiver under section 6661(c), they have not estab-
lished that respondent abused her discretion in not granting any
such request.
Based on the entire record before us, we find that petition-
ers have failed to satisfy their burden of proving that for 1983
they had substantial authority for claiming in their 1983 return
the loss of $13,919 and the investment tax credit of $20,899 with
respect to Ridge Energy, that that return position was more
likely than not the proper treatment, and that, assuming arguendo
that petitioners requested a waiver under section 6661(c),
respondent abused her discretion in not granting any such re-
quest. Accordingly, we sustain respondent's determination
imposing for 1983 the addition to tax under section 6661(a).
To reflect the foregoing,
Decision will be entered for
respondent.
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