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condition. In so doing, petitioner argues that section 72(m)
infringes upon his First Amendment right to free exercise of
religion, insofar as it would require him to violate his
religious beliefs before being accorded the benefits of the
exception to the 10-percent additional tax. We do not doubt the
sincerity of petitioner's religious beliefs. Nevertheless, we
have stated: "The fact that a law with a secular purpose may
have the effect of making the observance of some religious
beliefs more expensive does not render the statute
unconstitutional under the First Amendment." Black v.
Commissioner, 69 T.C. 505, 510 (1977) (citation omitted).
Section 72(m) has the purpose of requiring taxpayers to
furnish proof of disability before being entitled to a tax
benefit. See Dwyer v. Commissioner, 106 T.C. 337 (1996). By
choosing not to seek a medical diagnosis for his condition,
petitioner fails to qualify for this exception. We, therefore,
sustain respondent's determination on this issue.
5. Accuracy-Related Penalty Under Section 6662(a)
Respondent determined that petitioner was liable for the
accuracy-related penalty for 1991. The accuracy-related penalty
is equal to 20 percent of any portion of underpayment
attributable to a taxpayer's negligence or disregard of rules and
regulations. Sec. 6662(a) and (b)(1). The term "negligence"
includes any failure to make a reasonable attempt to comply with
the provisions of the Internal Revenue Code, and the term
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