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The factors evidencing intent to file a joint return are:
Lack of reason for a refusal to file a joint return, the absence
of objections by the nonsigning spouse, the delivery of tax data
to the husband for the purpose of making the tax return, and the
apparent advantage in filing a joint return. Heim v.
Commissioner, supra.
The Federal income tax returns petitioner submitted to
respondent reported taxable wage income of $223,776 for 1997 and
$274,080 for 1999. Petitioner’s wife received wage income of
$6,288 in 1997 and $9,759 in 1999. The wage income petitioner
reported on the Federal income tax returns does not include the
wage income received by his wife. The returns reflect only
petitioner’s wage income for 1997 and 1999.
There is no evidence that petitioner’s wife intended to file
a joint return with petitioner for 1997 or 1999. We conclude
that petitioner is not entitled to joint filing status for any of
the years in issue. Respondent’s determination is sustained.
V. 1997 Sale of Stock
On November 26, 1997, petitioner sold 700 shares of Barnett
Banks, Inc. stock. Respondent determined in the notice of
deficiency that petitioner had short-term capital gain on the
sale of 700 shares of stock.
Petitioner received proceeds of $49,568 from the sale of the
700 shares of stock. The parties stipulated that petitioner had
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