- 2 -
9700-00 (respondent’s motion in the case at docket No. 9700-00),
respondent’s motion to dismiss for lack of prosecution and to
impose sanctions under section 6673 in the case at docket No.
9701-00 (respondent’s motion in the case at docket No. 9701-00),
and respondent’s motion to hold petitioner in default in the case
at docket No. 9702-00 (respondent’s motion in the case at docket
No. 9702-00). (We shall refer collectively to those three
motions as respondent’s motions.) At the request of respondent,
on October 15, 2001, the Court held a trial in order to enable
respondent to present evidence to satisfy the burden of produc-
tion under section 7491(c) that respondent maintains respondent
has with respect to: (1) The accuracy-related penalty under
section 6662(a) that respondent determined for each of the
taxable years 1996 and 1997 in the notice of deficiency (notice)
issued to Mildred I. Criss (Ms. Criss) in the case at docket No.
9700-00; (2) the accuracy-related penalty under section 6662(a)
for each of the taxable years 1996 and 1997 that respondent
determined in the notice issued to Daryl E. Criss (Mr. Criss) in
the case at docket No. 9701-00; and (3) the addition to tax under
section 6651(a)(1) for the taxable year 1997 that respondent
determined in the notice issued to Criss Asset Management Trust
2(...continued)
(Code) in effect at all relevant times. All Rule references are
to the Tax Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011