Barry D. and Suzanne B. Whalley - Page 48

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          they were not entitled to claim, and failed to establish that the           
          expenses incurred during 1991 and 1992 were ordinary and                    
          necessary costs of carrying on a trade or business pursuant to              
          section 162.  Thus, we find that petitioners have failed to meet            
          their burden of proof with respect to the accuracy-related                  
          penalty.  Accordingly, we sustain respondent's determination that           
          petitioners are liable for the accuracy-related penalty pursuant            
          to section 6662(a).  Rule 142(a).                                           
               To reflect the foregoing,                                              
                                                                                     
          Decision will be entered                                                    
          under Rule 155.                                                             

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