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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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