Mildred I. Criss, et al. - Page 6




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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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