- 19 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
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