Mildred I. Criss, et al. - Page 3




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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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