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9700-00 filed a motion to dismiss that case, which the Court
denied on September 19, 2001. On October 9, 2001, Ms. Criss in
the case at docket No. 9700-00 filed a motion for entry of
judgment in favor of petitioner in that case, which the Court
denied on October 10, 2001. On October 9, 2001, Ms. Criss in the
case at docket No. 9700-00 filed a motion to continue the trial
in that case, which the Court denied on October 10, 2001.
On October 9, 2001, Mr. Criss in the case at docket No.
9701-00 filed a motion for entry of judgment in favor of peti-
tioner in that case, which the Court denied on October 10, 2001.
On October 9, 2001, Mr. Criss in the case at docket No. 9701-00
filed a motion to continue the trial in that case, which the
Court denied on October 10, 2001.
On October 15, 2001, these cases were called from the
Court’s trial calendar at the Court’s trial session in Cleveland,
Ohio (Cleveland trial session). At that calendar call, there was
no appearance by or on behalf of Ms. Criss, Mr. Criss, and Criss
Trust. At that time, respondent orally moved to dismiss each of
these cases for failure to prosecute, and respondent requested,
and the Court held, a trial because, according to respondent,
respondent has the burden of production pursuant to section
7491(c) with respect to the respective penalties under section
6662(a) for 1996 and 1997 that respondent determined against Ms.
Criss and against Mr. Criss and with respect to the addition to
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Last modified: May 25, 2011