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For the same reasons that we held petitioners negligent,
supra, we hold that petitioners did not have a reasonable basis
for the adjusted basis or valuation claimed on their tax return
with respect to the investment in Northeast. The record in this
case does not establish an abuse of discretion on the part of
respondent but supports respondent's position. We hold that
respondent's refusal to waive the section 6659 addition to tax in
this case 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.
Decision will be entered
under Rule 155.
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