- 3 - (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.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