- 8 -
United States, 783 F.2d 966 (10th Cir. 1986); Nieto v.
Commissioner, T.C. Memo. 1992-296. Thus, the Court concludes
that, pursuant to section 152(e), petitioner is not entitled to
claim his two children as dependents for 1992. His remedy, if
any, lies in the State court for enforcement of the divorce
decree.
Decision will be entered
for respondent.
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