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jurisdiction under the laws of which Criss Trust was purportedly
organized, (2) the person who is authorized to act on behalf of
Criss Trust, and (3) that Criss Trust was at all relevant times a
trust cognizable for Federal tax purposes. Nor did Criss Trust
at any time provide any books, records, or other information to
respondent establishing the income reported and the expense
deductions claimed in Criss Trust’s 1996 and 1997 trust returns.
In the notice issued to Criss Trust, respondent determined,
inter alia, that Criss Trust is liable (1) for each of the
taxable years 1996 and 1997 for the accuracy-related penalty
under section 6662(a) and (2) for the taxable year 1997 for the
addition to tax under section 6651(a)(1).
Criss Partnership filed Form 1065, U.S. Partnership Return
of Income (partnership return), for each of the taxable years
1996 and 1997. Each of Criss Partnership’s 1996 and 1997 part-
nership returns reported that Criss Partnership’s principal
business was a trucking activity. In Schedule K-1, Partner’s
Share of Income, Credits, Deductions, etc., that Criss Partner-
ship included with each of its 1996 and 1997 partnership returns,
Criss Partnership indicated that Mr. Criss was a 12-percent
general partner, and Ms. Criss was an 88-percent limited partner,
of Criss Partnership. The income that Criss Partnership reported
in its 1996 and 1997 partnership returns was generated from
assets owned solely by Mr. Criss.
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Last modified: May 25, 2011