Jackie H. Hunt - Page 14




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          case.  If disclosure is not made in compliance with the                     
          regulations or the revenue procedure, adequate disclosure on the            
          return may still be satisfied if sufficient information is                  
          provided to enable respondent to identify the potential                     
          controversy involved.  See Schirmer v. Commissioner, 89 T.C. 277,           
          285-286 (1987).  Petitioner argues that the deduction was clearly           
          indicated on the return.  Merely claiming the loss, without                 
          further explanation, was not sufficient to alert respondent to              
          the controversial section 174 deduction of which the partnership            
          loss consisted.                                                             
               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.            
          We review 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).  Petitioner argues that             
          she acted in good faith and reasonably relied upon Mr. Meinke and           
          Mr. Mussina in claiming the loss.  However, nothing in the record           
          indicates petitioner 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 petitioner did not have substantial authority for              
          her treatment of the partnership loss and did not adequately                






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