Daniel G. Callahan, et al. - Page 3




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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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