- 5 -
mined, inter alia, that Mr. Criss is liable for each of the
taxable 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).
Criss Trust filed Form 1041, U.S. Income Tax Return for
Estates and Trusts (trust return), for each of the taxable years
1996 and 1997. In Schedule K-1, Beneficiary’s Share of Income,
Deductions, Credits, etc. (Form 1041 Schedule K-1), that Criss
Trust included with each of its 1996 and 1997 trust returns,
Criss Trust indicated that Mr. Criss was a beneficiary and a
fiduciary of Criss Trust. In a separate Form 1041 Schedule K-1
that Criss Trust included with each of its 1996 and 1997 trust
returns, Criss Trust indicated that Ms. Criss was a beneficiary
of Criss Trust.
In each of its 1996 and 1997 trust returns, Criss Trust
deducted depreciation with respect to Ms. Criss’ personal resi-
dence that she had transferred to Criss Trust at a time that is
not disclosed by the record. Criss Trust also deducted other
amounts in its 1996 and 1997 trust returns for personal expenses
of Ms. Criss and/or Mr. Criss.
During respondent’s examination of Criss Trust’s 1996 and
1997 trust returns and thereafter, no books, records, or other
information was provided to respondent establishing (1) the
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