Janet E. Crowell - Page 7

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          Form 8332, Release of Claim to Exemption for Child of Divorced or           
          Separated Parents, requires the (1) name of the children for                
          which exemption claims were released, (2) years for which the               
          claims were released, (3) signature of the custodial parent, (4)            
          Social Security number of the custodial parent, (5) date of                 
          signature, and (6) name and Social Security number of the parent            
          claiming the exemption.                                                     
               In this case, Mr. Crowell attached to his 1998 and 1999                
          Federal income tax returns a Form 8332 signed by Mrs. Crowell               
          with respect to the dependency exemption deductions for their               
          children.  Part I of that form, Release of Claim to Exemption for           
          Current Year, allows Mr. Crowell the dependency exemptions for              
          Cody, David, Ben, Beth, and Adam for the year 1995.  Part II of             
          that form, Release of Claim to Exemption for Future Years, allows           
          Mr. Crowell dependency exemption deductions for Cody, David, Ben,           
          and Beth for 11 years, 1996 through 2006.  Both Parts I and II of           
          the form are dated August 2, 1996.  Respondent, in the notice of            
          deficiency to Mr. Crowell, disregarded without explanation the              
          Form 8332 and disallowed the dependency exemption deductions                
          claimed for the four children for 1998 and 1999.  Respondent                
          likewise disallowed the four dependency exemption deductions for            


          3(...continued)                                                             
          Corp. v. Commissioner, 751 F.2d 123, 127 (2d Cir. 1984), revg. on           
          other grounds T.C. Memo. 1984-145.                                          





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