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sufficient information is provided to enable respondent to
identify the potential controversy involved. Schirmer v.
Commissioner, 89 T.C. 277, 285-286 (1987). However, a mere
claiming of the loss, without further explanation, is not
sufficient to alert respondent to the controversial section 174
deduction of which the partnership loss consisted. Petitioners
have failed to show that the relevant facts pertaining to their
Blythe II loss deduction were adequately disclosed on their 1982
return.12
Finally, section 6661(c) provides the Secretary with the
discretion to waive the section 6661(a) addition to tax if the
taxpayer shows he acted with reasonable cause and in good faith.
This Court reviews the Secretary’s failure to waive the addition
to tax for abuse of discretion. See Martin Ice Cream Co. v.
Commissioner, 110 T.C. 189, 235 (1998). Petitioners argue that
they acted in good faith and reasonably relied upon the advice of
Mr. Hulse in claiming the relevant loss. However, nothing in the
record indicates that petitioners requested a waiver for good
faith and reasonable cause under section 6661(c). In the absence
of such a request, this Court cannot review respondent’s
determination for an abuse of discretion. See id. In any event,
12 As noted earlier, even if an adequate disclosure had
been made on the return, such disclosure would not reduce the
amount of the understatement attributable to a tax shelter item.
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