Charles A. and Marian L. Derby, et al. - Page 4

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          petitioners Charles A. and Marian L. Derby (the Derbys)                     
          underreported the 1994 income from Dr. Derby's S corporation by             
                                  FINDINGS OF FACT4                                   
               Some facts are stipulated and are so found.  The stipulation           
          of facts, with accompanying exhibits, is incorporated herein by             
          this reference.                                                             
          I.   Petitioners                                                            
               When they filed their petitions in these consolidated cases,           
          petitioners Charles A. and Marian L. Derby, Peter E. and                    
          Geraldine Droubay, James W. and Marilee G. Eusebio, Michael A.              
          and Linda S. Hirsch, John F. Hoefer and Elise R. Smith-Hoefer,              
          Daniel J. and Sean C. Kennedy, Harris D. and Barbara F. Levin,              
          Gerald R. MacLean and Joan L. Smith-MacLean, Hugh A. and                    
          Elizabeth K. Patterson, Robert S. and Susan C. Silva, and Richard           
          H. White and Paula A. Watts-White, resided in California;                   
          petitioners Michael R. and Ann J. Harris resided in Oregon.                 
          During the taxable year ended December 31, 1994, Women's Health             
          Associates (WHA) was a partnership as defined by section                    
          6231(a)(1).  Its principal place of business was in California.             

               4 To the extent that petitioners have failed to set forth              
          objections to respondent's proposed findings of fact, or vice               
          versa, we conclude that these proposed findings of fact are                 
          correct except to the extent that the nonobjecting party's                  
          proposed findings of fact are clearly inconsistent therewith.               
          See Jonson v. Commissioner, 118 T.C. 106, 108 n.4 (2002), affd.             
          353 F.3d 1181 (10th Cir. 2003).                                             

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