Oliver W. and Edna D. Wilson - Page 53

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          respondent’s determination that petitioners are liable for the              
          section 6662(a) accuracy-related penalty for 1993 with respect to           
          that part of underpayment attributable to their deduction of a              
          prior year’s unallowed passive loss.  Rule 142(a).                          
               In light of the foregoing and to reflect concessions made by           
          the parties,                                                                
                                                  Decisions will be entered           
                                             under Rule 155.                          























               20(...continued)                                                       
          had reasonable cause for their deduction of the loss.  Because              
          petitioners made no credible attempt to explain the loss, or to             
          justify their deduction of it, we reject petitioners’ argument              
          that the penalty should not apply to respondent’s adjustment                
          disallowing the loss.                                                       

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