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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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Last modified: November 10, 2007