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other before or after the annulment. Petitioners supplied
information to the Texas State court that conflicted with
information Ms. Yeager provided to the Bankruptcy court, Mr.
Rinehart provided to his employer, and Ms. Yeager provided to a
Washington State court in her Complaint for Declaratory Judgment.
Petitioners’ annulment was grounded on their collusive
falsehoods. Mr. Rinehart was wrong when, in seeking an annulment
from the Texas State court, he stated that Ms. Yeager’s marriage
to Mr. Williams had not been dissolved by divorce. Likewise, Ms.
Yeager was wrong when, in acceding to the annulment, she
represented to the Texas State court that her divorce action with
Mr. Williams was not final and was still pending in Washington
State. These were not honest mistakes.
Based on the foregoing,11 we sustain respondent’s
11 We note that there is an additional reason for
disregarding the annulment for tax purposes. In general, an
annulment has the effect of declaring a marriage void ab initio
under Texas law. Home of the Holy Infancy v. Kaska, 397 S.W.2d
208, 212 (Tex. 1966). It thus “relates back” to erase the
marriage from the outset. Id. The doctrine of relation back,
however, is not absolute in Texas. Harris v. R.R. Ret. Bd., 3
F.3d 131, 134 (5th Cir. 1993). Courts have recognized that
annulment is a legal fiction and the relation back doctrine is a
limited concept. Id.; Home of the Holy Infancy v. Kaska, supra
at 212. “(I)n cases involving the rights of third parties,
courts have been especially wary lest the logical appeal of the
fiction should obscure fundamental problems and lead to unjust or
ill-advised results respecting a third party’s rights.” Home of
the Holy Infancy v. Kaska, supra at 212 (quoting Sefton v.
Sefton, 291 P.2d 439, 441 (Cal. 1955)).
In the present case, Mr. Rinehart filed his petition for an
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