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(Criss Trust)3 in the case at docket No. 9702-00.4
Background
The record establishes and/or the parties do not dispute the
following:
At the time the respective petitions in these cases were
filed, Ms. Criss, Mr. Criss, and Criss Trust listed in those
petitions the same address in Massillon, Ohio.
Ms. Criss filed Form 1040, U.S. Individual Income Tax Return
(return), for each of the taxable years 1996 and 1997. During
respondent’s examination of Ms. Criss’ 1996 and 1997 returns and
thereafter, Ms. Criss provided no books, records, or other
information to respondent establishing the income reported and
the expense deductions claimed in those returns.
In the notice issued to Ms. Criss, respondent determined,
inter alia, that Ms. Criss is liable for each of the taxable
3When referring in this Opinion to Criss Asset Management
Trust and Criss Trust, our use of the word “Trust” and any
similar words is for convenience only and is not intended to
convey any meaning or have any significance for Federal tax
purposes.
4In the notice issued to Criss Trust, respondent also deter-
mined to impose the accuracy-related penalty under sec. 6662(a)
for each of the taxable years 1996 and 1997. At the trial,
respondent indicated that respondent was abandoning pursuing the
determinations in the notice issued to Criss Trust to impose the
penalty under sec. 6662(a) for each of the taxable years 1996 and
1997. In respondent’s brief filed after the trial, respondent
makes no reference to the addition to tax under sec. 6651(a)(1)
for the taxable year 1997 that respondent determined in the
notice issued to Criss Trust.
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