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The only issue is whether petitioner is entitled to a joint
filing status.
The facts may be summarized as follows. Prior to 1993,
petitioner and Maliheh Chasevi (Ms. Chasevi) were married, lived
together in Florida, and had filed joint Federal income tax
returns in the previous years. In April 1993, they separated,
and petitioner moved to Georgia. In late 1993 or early 1994, Ms.
Chasevi inquired whether petitioner would file a joint return
with her for the 1993 taxable year. Petitioner agreed, and Ms.
Chasevi sent her Form W-2 from her employer to him.
In April 1994, petitioner could not pay the amount due and
requested an extension of time for filing the 1993 return.
Sometime later, Ms. Chasevi questioned him about whether a return
had been filed. Petitioner got "upset" but did tell her that he
had not filed, and then told her to file her own return. Ms.
Chasevi filed a separate return for the taxable year 1993 in
April 1995. Shortly thereafter petitioner filed a purported
joint return for the taxable year 1993. Ms. Chasevi did not sign
the return. Petitioner signed her name to the return. Ms.
Chasevi did not know that the purported joint return had been
filed until October 1995, and she has not ratified the purported
joint return in any fashion.
Upon examination of the purported joint return filed by
petitioner, respondent disallowed the dependency exemption
claimed for Ms. Chasevi, removed her income from the gross
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