Daniel C. Noonan - Page 14

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               Based on the record, we conclude that Mrs. Noonan intended             
          to file a joint return with petitioner for 1988.  Thus,                     
          petitioner is entitled to joint filing status for 1988.6                    

                                                  Decision will be entered            
                                             for petitioner.                          





























          6  In view of our conclusion on the first issue, the sec.                   
          6651 issue is moot and requires no further discussion.                      




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