Stuart A. and Harriet J. Gollin, et al. - Page 83

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          scope of expertise and experience of their advisers.                        
          Consequently, we consider petitioners' reliance on the Mauerman             
          case inappropriate.                                                         
               We hold that petitioners did not have a reasonable basis for           
          the adjusted bases or valuations claimed on their tax returns               
          with respect to their investments in the Partnerships.  In these            
          cases, respondent could find that petitioners' respective                   
          reliance on the offering materials, Becker, and Hertan was                  
          unreasonable.  The records in these cases do not establish an               
          abuse of discretion on the part of respondent but support                   
          respondent's position.  We hold that respondent's refusal to                
          waive the section 6659 addition to tax is not an abuse of                   
          discretion.  Petitioners are liable for the respective section              
          6659 additions to tax at the rate of 30 percent of the                      
          underpayments of tax attributable to the disallowed tax benefits.           
          Respondent is sustained on this issue.                                      
          C. Petitioners' Motions For Leave To File Motion For Decision               
          Ordering Relief From the Negligence Penalty and the Penalty Rate            
          of Interest and To File Supporting Memorandum of Law                        
               Long after the trials of these cases, petitioners Gollin and           
          Fishbach each filed a Motion For Leave To File Motion For                   
          Decision Ordering Relief From the Negligence Penalty and the                
          Penalty Rate of Interest and To File Supporting Memorandum of Law           
          under Rule 50.  Petitioners Gollin and Fishbach also lodged with            
          the Court motions for decision ordering relief from the additions           
          to tax for negligence and from the increased rate of interest,              




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