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v. Commissioner, 99 T.C. 132, 179 (1992). On the record before
us, we are unable to conclude that respondent abused his
discretion. First, we are unable to find that petitioner ever
asked respondent to exercise his discretion before he issued the
notice of deficiency to her. Absent a timely request for a
waiver, which we do not find was present here, we cannot hold
that respondent abused his discretion in not waiving an addition
to tax under section 6659. See Martin Ice Cream Co. v.
Commissioner, 110 T.C. 189, 234-235 (1998); Haught v.
Commissioner, T.C. Memo. 1993-58; cf. Lapin v. Commissioner, T.C.
Memo. 1990-343, affd. without published opinion 956 F.2d 1167
(9th Cir. 1992).
Even if petitioner had made such a timely request, we find
nothing in the record to establish that she had the requisite
reasonable basis for the overstated valuation to overcome
respondent’s determination. The mere fact that she relied on Mr.
Kanter, a tax professional, in choosing to participate in Degree
does not mean that she reasonably reported the overstated
valuation on her income tax return. Indeed, the facts of this
case, including the facts that petitioner was aware of Mr.
Kanter’s qualifications from their longtime close business
relationship, that Mr. Kanter was not professionally qualified to
evaluate or appraise the energy management systems equipment,
that petitioner never read the PPM, and that petitioner never
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