- 4 - petitioners Charles A. and Marian L. Derby (the Derbys) underreported the 1994 income from Dr. Derby's S corporation by $3,665. 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008