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34459 (Aug. 31, 1984).1
For a noncustodial parent to satisfy the written declaration
requirement of section 152(e)(2), the custodial parent is
required to provide the following on Form 8332, or a statement
conforming to the substance of Form 8332: (1) The names of the
children with respect to whom the exemptions are released; (2)
the years for which the claims to exemptions are released to the
noncustodial parent; (3) the signature of the custodial parent
confirming his or her consent; (4) the Social Security number of
the custodial parent; (5) the date of the custodial parent’s
signature; and (6) the name and Social Security number of the
parent claiming the exemption. Miller v. Commissioner, 114 T.C.
184, 190 (2000), affd. on another ground sub nom. Lovejoy v.
Commissioner, 293 F.3d 1208 (10th Cir. 2002). Satisfying the
signature requirement is critical to the successful release of
the dependency exemption within the meaning of section 152(e)(2).
Id.; see Horn v. Commissioner, T.C. Memo. 2002-290; Neal v.
Commissioner, T.C. Memo. 1999-97. In addition, “the signature of
the custodial parent must confirm the custodial parent’s
intention to release the dependency exemption to the noncustodial
1 Temporary regulations are entitled to the same weight as
final regulations. Peterson Marital Trust v. Commissioner, 102
T.C. 790, 797 (1994), affd. 78 F.3d 795 (2d Cir. 1996); Truck &
Equip. Corp. v. Commissioner, 98 T.C. 141, 149 (1992).
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