- 72 - of section 6653(a), the evidence before us on that issue was not completely uncontroverted, especially in light of petitioner’s failure to disclose the split-off on its 1988 income tax return. We therefore cannot say that reasonable cause and good faith were so clear that any refusal by respondent to waive the addition to tax would have amounted to an abuse of discretion as being without sound basis in fact. See, e.g., Vandeyacht v. Commissioner, T.C. Memo. 1994-148; Klavan v. Commissioner, T.C. Memo. 1993-299. Accordingly, we sustain respondent’s determination that petitioner is liable for the section 6661(a) addition to tax on the underpayment. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72
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