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however, without further explanation, was not sufficient to alert
respondent to the controversial section 174 deduction of which
the partnership loss consisted. Petitioners have failed to
present evidence to show that the relevant facts pertaining to
their Blythe II loss deduction were adequately disclosed on their
1982 return.13
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.
This Court reviews for abuse of discretion the Secretary's
failure to waive the addition to tax for abuse of discretion.
Martin Ice Cream Co. v. Commissioner, 110 T.C. 189, 235 (1998).
Petitioners argue that they acted in good faith and reasonably
relied upon the advice of Mr. Meyers in claiming the relevant
loss. However, nothing in the record indicates that petitioners
requested a waiver for good faith and reasonable cause under
section 6661(c). In the absence of such a request, this Court
cannot review respondent's determination for an abuse of
discretion. Id. In any event, petitioners have not shown that
they met the tests of reasonable cause and good faith.
Petitioners have failed to prove that they had substantial
authority for their treatment of the partnership loss and that
13 As noted earlier, even if an adequate disclosure had
been made on the return, such a disclosure would not reduce the
amount of the understatement attributable to a tax shelter item.
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