In a Chief Counsel Advice, the IRS has said that it will presume that an entity is a partnership when a "husband and wife" own the entity unless, of course, an election is made for the entity to be disregarded for tax purposes. The IRS cited I.R.C. Sec. 761(a) & (f) as the basis for its conclusion. Only additional facts indicating a sham will cause the IRS to disregard the "wife" as the partner, IRS stated. IRS also indicated that each spouse should have reported "his/her" share of net earning from self-employment, with appropriate adjustments. The IRS did not indicate how entities owned by homosexual couples are to be treated. C.C.A. 201411035 (Apr. 12, 2013).