Karen Ann Keegan - Page 16

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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                            
                  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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