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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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