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quirement set forth in section 6012(a)(1)(A). As pertinent here,
section 6012(a)(1)(A)(ii) provides that an individual who quali-
fies as a "Head of household"--a term defined in section
6012(a)(1)(A)(i) to have the same meaning as provided in section
2(b)--is not required to file a return if that individual's gross
income for the taxable year is less than the sum of the exemption
amount and the "basic standard deduction" applicable to such
individual. The term "basic standard deduction" is defined in
section 6012(a)(1)(D)(i) to have the same meaning as provided in
section 63(c)(2). According to the return that petitioner filed
late for each of the years 1989 and 1990, his gross income
exceeded the sum of the exemption amount and the basic standard
deduction for each such year. He therefore was required to file
a return for each of the years 1989 and 1990.
On the instant record, we find that petitioner has failed to
satisfy his burden of proving that his failure to file timely his
returns for 1989 and 1990 was due to reasonable cause, and not
willful neglect. Accordingly, we sustain respondent's determina-
tions for those years imposing the addition to tax under section
6651(a)(1).
Section 6662(a)
Section 6662(a) imposes a penalty equal to 20 percent of the
underpayment of tax attributable to, inter alia, any substantial
understatement of income tax. Sec. 6662(b)(2). With respect to
individuals, an understatement of income tax is substantial if it
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