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California Revenue And Taxation Code Section 18531

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For the purposes of Chapter 9 (commencing with Section
19701) which relates to criminal penalties in the case of fraudulent
returns, the term "return" includes a separate return filed by a
spouse with respect to a taxable year for which a joint return is
made under Section 18522 after the filing of the separate return.

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Last modified: January 12, 2009