- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007