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years 1996 and 1997 for the accuracy-related penalty under
section 6662(a) because of: (1) Negligence or disregard of rules
or regulations under section 6662(b)(1) or (2) substantial
understatement of income tax under section 6662(b)(2).
Prior to and including the tax years 1996 and 1997, Mr.
Criss, Ms. Criss’ son, operated a trucking business.
Mr. Criss filed a return for each of the taxable years 1996
and 1997. According to the respective Schedules C, Profit or
Loss From Business (Schedule C), included with Mr. Criss’ 1996
and 1997 returns, Mr. Criss received income from his trucking
business of $115,483 for 1996 and $75,560 for 1997. In each of
Mr. Criss’ 1996 and 1997 Schedules C, Mr. Criss indicated that
his Schedule C trucking business income was reported by or
assigned to employer identification No. (EIN) 34-1840319, which
was the EIN for Criss Family Limited Partnership (Criss Partner-
ship).5
During respondent’s examination of Mr. Criss’ 1996 and 1997
returns and thereafter, Mr. 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 that respondent issued to Mr. Criss, respondent deter-
5When referring in this Opinion to Criss Family Limited
Partnership and Criss Partnership, our use of the word “Partner-
ship” and any similar words is for convenience only and is not
intended to convey any meaning for Federal tax purposes.
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Last modified: May 25, 2011