Terry U. Neal - Page 10




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          to his returns a copy of his divorce decree and dependency                  
          exemption order granting him the right to claim the child                   
          dependency exemptions.  Although the publications upon which                
          petitioner contends he relied were not introduced into evidence,            
          the testimony indicates that these publications required that any           
          document attached to the return for purposes of satisfying                  
          section 152(e)(2) must contain the signature of the custodial               
          parent.  This sort of requirement in a publication would                    
          certainly correspond to the statutory provisions of section                 
          152(e)(2) and the regulations thereunder.  Although petitioner              
          attached copies of the divorce decree and dependency exemption              
          order to his returns for 1994, 1995, and 1996, these documents              
          provide that petitioner is entitled to claim a dependency                   
          exemption for Nathan only.  Moreover, petitioner admits that he             
          failed to attach a signature page for either of these documents,            
          as required by the publication, containing the signature of Ms.             
          Mosley.  Petitioner argues that the State of Kentucky does not              
          require signatures of the parties on divorce decrees; thus, he              
          should not be required to attach to his returns a document                  
          containing Ms. Mosley's signature.                                          
               Petitioner's argument in this regard is misplaced.  An                 
          obvious purpose of the aforementioned IRS publications is to                
          insure that taxpayers understand the requirements for compliance            
          with section 152(e)(2) and the corresponding regulations.                   





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