Section 18531 Of Article 1. Individuals And Fiduciaries From California Revenue And Taxation Code >> Division 2. >> Part 10.2. >> Chapter 2. >> Article 1.

. 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.