HANLEY, J.
The following issues are presented on appeal:
1. Does the filing of a federal joint income tax return create a right under federal law to an interest in a refund resulting therefrom in the spouse to whom no substantial income or deductions are attributable?
2. Does the filing of a federal joint income tax return operate as a transfer, conveyance or assignment of an individual's interest in the income to his spouse to whom no substantial...
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