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whether petitioners are liable for additions to tax under section
6654 for those years; and (5) whether petitioners are liable for
penalties under section 6673(a)(1).
FINDINGS OF FACT
Some of the facts have been stipulated and are incorporated
by this reference. At the time the petitions were filed,
petitioners resided in Wisconsin.
Mr. Callahan and Mrs. Callahan were married in 1990 and have
resided together in the same household in Wisconsin since that
time, through the years in issue. Petitioners do not have a
marital property agreement and have not opted out of the marital
property laws of Wisconsin.
Mrs. Callahan provided medical services at a medical group
in Racine, Wisconsin. For her services as a nurse practitioner,
she received payments of $51,117, $51,092, $53,630, and $59,656
in 1997, 1998, 1999, and 2002, respectively. She received
dividend income of $151, $177, $210, and $221 in 1997, 1998,
1999, and 2002, respectively, as well as interest income of $26
in 1999 and $26 in 2002.
Mr. Callahan received payment of $1,000 from Idea Consulting
in 1998, as well as interest income of $36 and $30 in 1997 and
1998, respectively. He also received $41,290 as compensation for
his services from J. Tyson & Associates in 2002.
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