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demonstrates that there was reasonable cause for his underpayment
and that he acted in good faith. Sec. 6661(c). The taxpayer in
Mauerman relied upon independent attorneys and accountants for
advice as to whether payments were properly deductible or
capitalized. The advice relied upon by the taxpayer in Mauerman
was within the scope of the advisers' expertise, the
interpretation of the tax laws as applied to undisputed facts.
In these cases, particularly with respect to valuation,
petitioners relied upon advice that 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 claimed on their tax returns
with respect to their investments in the Partnerships. In these
cases, respondent properly could find that petitioners'
respective reliance on the offering materials, Becker, Steele,
and/or Sprague 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
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