- 15 - abuse of discretion. See McCoy Enterprises, Inc. v. Commissioner, 58 F.3d 557, 562-563 (10th Cir. 1995) affg. T.C. Memo. 1992-693. Nothing in the record indicates petitioners requested a waiver for good faith and reasonable cause under section 6661(c). In the absence of such a request, we cannot review respondent’s determination for an abuse of discretion. See id. Because petitioners have not established either that they had substantial authority for their treatment of the partnership loss or that they adequately disclosed the relevant facts of that treatment, we uphold respondent’s determination on this issue. 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
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