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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, the Court finds that the November 6, 1989,
letter signed by Ms. White fails to "conform to the substance" of
Form 8332. Sec. 1.152-4T(a), Q&A-3, Temporary Income Tax Regs.
The letter fails to state the years in which Ms. White was
releasing the claims for exemption, nor does the letter state the
Social Security numbers of either parent. Most importantly, the
letter fails to explicitly state that Ms. White would not claim
Christopher and Allison as dependents. In fact, for 1992, Ms.
White did claim the children as dependents. The letter relied on
by petitioner is essentially nothing more than a restatement of
the divorce decree. It has no other meaning or significance.
While the Court sympathizes with petitioner and understands
petitioner's intentions in having Ms. White sign the letter
prepared by him, unfortunately, the requirements of section
152(e)(2)(A) have not been met in this case.
Although petitioner's divorce decree provides that he is
entitled to the dependency exemptions for the two children, State
courts, by their decisions, cannot determine issues of Federal
tax law. Commissioner v. Tower, 327 U.S. 280 (1946); Kenfield v.
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