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
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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Last modified: March 27, 2008