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to file a timely return because the taxpayer thought that no
taxes were due does not constitute reasonable cause within the
meaning of section 6651(a)(1). See Colbert v. Commissioner, T.C.
Memo. 1992-30, and cases cited therein. Accordingly, we hold
that petitioner is liable for the additions to tax under section
6651(a)(1) for 1989 and 1992.
3. Section 6662(a) Accuracy-related Penalty
Section 6662(a) provides that if any portion of an
underpayment of tax is attributable to negligence or disregard of
rules or regulations, then there shall be added to the tax an
amount equal to 20 percent of the amount of the underpayment
which is so attributable. The term "negligence" includes any
failure to make a reasonable attempt to comply with the statute,
and the term "disregard" includes any careless, reckless, or
intentional disregard. Sec. 6662(c).
Petitioner bears the burden of proving that he is not liable
for the accuracy-related penalty. Rule 142(a); INDOPCO, Inc. v.
Commissioner, supra; Welch v. Helvering, supra.
Petitioner did not address the penalty for negligence at
trial and therefore failed to carry his burden of proof. In any
event, we note that petitioner's failure to maintain accurate and
complete records of his gambling activity would suffice to
sustain respondent's determination. Accordingly, we hold that
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