David Dental, DDS, and his unmarried partner Sally Surgeon, MD have lived together for the past five years. Both are at the peak of their careers and decide to buy a new show case home in La Jolla, California. After looking at several homes in the area, they buy one for $ 2 million. They put a 20 percent down payment ($ 400,000) on the house and finance the balance ($ 1.6 million). Each takes out a separate mort-gage for $ 800,000 for a total $ 1.6 million. There is no additional debt (e. g., a home equity loan) on the residence.

a. Locate the chief counsel advice (CCA) that deals with this situation. Give the CCA citation.