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tax under section 6651(a)(1) for 1997 that respondent determined
against Criss Trust.6 At the trial in these cases on October 15,
2001, there was no appearance by or on behalf of Ms. Criss, Mr.
Criss, or Criss Trust.
On November 13, 2001, respondent filed a written motion to
dismiss for lack of prosecution and to impose sanctions under
section 6673 in the case at docket No. 9700-00, a written motion
to dismiss for lack of prosecution and to impose sanctions under
section 6673 in the case at docket No. 9701-00, and a written
motion to hold petitioner in default in the case at docket No.
9702-00.
On December 3, 2001, the Court sua sponte issued an Order
(December 3, 2001 Show Cause Order) directing each party in the
case at docket No. 9702-00 in which Criss Asset Management Trust
is named as petitioner to
show cause in writing why the Court has jurisdiction
over this case, including the identity of any purported
fiduciary of petitioner and a detailed analysis of why
such purported fiduciary has the capacity to litigate
in the Court on behalf of petitioner.
On December 19, 2001, respondent filed a written response to
the December 3, 2001 Show Cause Order in which respondent con-
tended, inter alia, that
6However, in the brief that respondent filed after the
trial, respondent makes no mention of respondent’s determination
that Criss Trust is liable for the addition to tax under sec.
6651(a)(1). See supra note 4.
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