return
(5) Additions to the tax and penalties (A) Coordination with part II of subchapter A of chapter 68 For purposes of part II of subchapter A of chapter 68, where the sum of the amounts shown as tax on the separate returns of each spouse is less than the amount shown as tax on the joint return made under this subsection— (i) such sum shall be treated as the amount shown on the joint return, (ii) any negligence (or disregard of rules or regulations) on either separate return shall be treated as negligence (or such disregard) on the joint return, and (iii) any fraud on either separate return shall be treated as fraud on the joint return. (B) Criminal penalty For purposes of section 7206(1) and (2) and section 7207 (relating 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 this subsection after the filing of such separate return.