Peter and Ursula Reimann, et al. - Page 49

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          petitioners relied upon advice which was outside the scope of               
          expertise and experience of their advisers.  Consequently, we               
          consider petitioners' reliance on the Mauerman case inapplicable.           
               We hold that petitioners did not have a reasonable basis for           
          the adjusted bases or valuations reflected on their tax returns             
          with respect to their investments in Scarborough and Plymouth.              
          In these cases respondent properly could find that petitioners'             
          respective reliance on Bachmann and Greene, and in varying                  
          degrees the offering materials, 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                 
          section 6659 addition to tax at the rate of 30 percent of the               
          underpayment of tax attributable to the disallowed tax benefits.            
          Respondent is sustained on this issue.                                      

                                             Decisions will be entered                
                                        under Rule 155.                               















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