- 2 - Daniel G. Callahan Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1997 $2,936 $734.00 $157.07 1998 3,064 766.00 140.23 1999 3,086 771.50 149.34 Mary E. Callahan Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1997 $9,971 $1,337.75 $258.82 1998 9,994 1,330.50 219.77 1999 10,509 1,373.00 238.80 2002 10,433 3,129.90 348.64 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. These cases were consolidated for trial, briefing, and opinion. At trial, respondent moved to amend the pleadings to conform to the proof, to the effect that petitioner Mary E. Callahan (Mrs. Callahan) was required to report one-half of petitioner Daniel G. Callahan’s (Mr. Callahan) income of $41,290 for 2002. We must decide the following issues: (1) Whether petitioners had unreported income in 1997, 1998, 1999, and 2002, as respondent determined; (2) whether petitioners must split their income in each year at issue on account of Wisconsin’s marital property laws; (3) whether petitioners are liable for additions to tax under section 6651(a)(1) for those years; (4)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007