- 3 - 1994-607, and Shackelford v. Commissioner, T.C. Memo. 1995-484, respectively.3 Respondent and petitioners agreed to be bound by the outcome of the above-referenced opinions. The above- referenced opinions hold that the taxpayers were married for Federal income tax purposes, although they had subsequently obtained annulments of their marriages under the laws of the State of California. Accordingly, petitioners’ filing status should have been “married filing separately” for purposes of their 1989 tax year. Petitioners, at all pertinent times, were certified public accountants, with more than 60 years of experience between them, practicing together in an accounting partnership known as Maynard & McDonald (M&M). There was no written partnership agreement through the 1989 tax year. McDonald is also an attorney licensed to practice in the State of Oklahoma. M&M is a cash basis partnership that petitioners formed in 1976 and operated during the 1989 taxable year in Sacramento, California. M&M’s principal activities are tax return preparation, assistance to clients in tax-related matters, providing accounting services, and representing clients before various administrative levels of the Internal Revenue Service. In addition, McDonald also filed clients’ petitions with this Court. McDonald was familiar with 3 Petitioners were either the parties in the underlying cases or referenced in several recent opinions issued by this Court. See Bill McDonald, et al. v. Commissioner, T.C. Memo. 1994-607; Denver W. McDonald v. Commissioner, T.C. Memo. 1995- 359; Betty J. Shackelford v. Commissioner, T.C. Memo. 1995-484; and Mary C. McDonald v. Commissioner, T.C. Memo. 1995-503.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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