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Petitioner claimed head-of-household filing status on her
returns for the taxable years 1994 and 1995. Under section
2(b)(1), a taxpayer who is unmarried may file a return as "head
of household" if that taxpayer maintains as his or her home a
household which constitutes for more than one-half of such
taxable year the principal place of abode of certain described
individuals.
In this case, petitioner has failed to establish that she
maintained a household within the meaning of section 2(b).
Petitioner neither owned nor paid rent for the house where Windi
or Mr. Gorges resided during the taxable years in question.
Moreover, Mr. Gorges is not a person who comes within the
provisions of section 2(b)(1) and section 151. Accordingly, we
sustain respondent on this issue.
4. Accuracy-Related Penalty Under Section 6662(a)
Respondent determined that petitioner was liable for the
accuracy-related penalty under section 6662(a) for the taxable
years 1994 and 1995. The accuracy-related penalty is equal to 20
percent of any portion of an underpayment attributable to a
taxpayer's negligence or disregard of rules or 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 "disregard" includes any
careless, reckless, or intentional disregard. Sec. 6662(c). The
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