Michael G. Harvey and Penny B. Harvey - Page 15




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          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.                               
























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