Mildred I. Criss, et al. - Page 5




                                        - 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