- 8 -
did not file returns for the years at issue, all of these items
of income must be equally split between them.
Unreported Income
Petitioners have admitted the receipt of each item of income
respondent determined. Their arguments that this income was not
taxable are frivolous tax-protester arguments that we need not
“refute * * * with somber reasoning and copious citation of
precedent; to do so might suggest that these arguments have some
colorable merit.” Crain v. Commissioner, 737 F.2d 1417, 1417
(5th Cir. 1984). After splitting each item of income at issue
equally between petitioners and attributing half of Mr.
Callahan’s 2002 income to Mrs. Callahan, we conclude that
petitioners had unreported income in the following amounts:
Mr. Callahan
Compensation for Dividends &
Year Services Interest Marital Income
1997 -0- $18 $25,634
1998 $500 15 25,635
1999 -0- -0- 26,933
Mrs. Callahan
Compensation for Dividends &
Year Services Interest Marital Income
1997 $25,559 $76 $18
1998 25,546 89 515
1999 26,815 118 -0-
2002 29,828 124 20,645
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