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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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