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household. Under section 2(b)(1)(A)(i), an individual such as
petitioner will qualify for head of household status if he
maintains as his home a household that is the principal place of
abode of a son or daughter for more than one-half of the taxable
year. The record establishes that petitioner did not reside with
Keauna during the subject years and does not establish that Zik
resided with him either.
6. Addition to Tax/Accuracy-Related Penalties
Section 6651(a)(1) imposes an addition to tax for failing to
file a return on or before the specified filing date unless it is
shown that this failure is due to reasonable cause and not due to
willful neglect. Reasonable cause may exist if a taxpayer
exercised ordinary business care and prudence and was nonetheless
unable to file the return within the date prescribed by law.
Sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect
means a “conscious, intentional failure or reckless
indifference.” United States v. Boyle, 469 U.S. 241, 245 (1985).
Section 6662(a) imposes a penalty of 20 percent on the
portion of an underpayment of tax attributable to, among other
things, a substantial understatement of tax. Sec. 6662(b)(1) and
(2). A substantial understatement of tax is one that exceeds the
greater of 10 percent of the tax required to be shown on the
return or $5,000. Sec. 6662(d)(1)(A). An accuracy-related
penalty does not apply to any portion of an understatement as to
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