Walter E. Hess and Helen L. Hess - Page 21

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          commissions.  He also claimed a deduction for a $170,040 loss on            
          his sales territory, knowing that he had no basis therein, that             
          he still worked in this territory after leaving Balfour, and that           
          the District Court had rejected his claim to have suffered such a           
          loss.  We conclude that petitioner is liable for the accuracy-              
          related penalty determined by respondent under section 6662(a)              
          for 1993.                                                                   
               In reaching all our holdings herein, we have considered all            
          arguments made by petitioner and, to the extent not discussed               
          above, find them to be without merit.  To reflect the foregoing,            

                                                  Decision will be entered            
                                             under Rule 155.                          

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