- 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.
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