Daniel G. Callahan, et al. - Page 2




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          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)              







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