- 2 - returns as support for the claimed dependency exemptions. The Permanent Orders were not signed by W consenting to the release of the dependency exemptions to H. The Permanent Orders were executed by the State court judge and were signed by W’s attorney signifying approval as to form. Held: The Permanent Orders do not qualify as a written declaration signed by the custodial parent confirming that the custodial parent will not claim the children as dependents for 1993 and 1994. Thus, attaching the Permanent Orders to H’s tax returns did not satisfy the requirements of sec. 152(e)(2), I.R.C. and H is not entitled to claim the dependency exemptions for his minor children. William C. Waller, Jr., for petitioner in docket No. 8094-97. Thomas G. Hodel, for petitioner in docket No. 8158-97. Sara J. Barkley, for respondent. MARVEL, Judge: Respondent determined deficiencies in the Federal income tax of petitioner Cheryl J. Miller, formerly Cheryl J. Lovejoy (Ms. Miller), for the taxable years 1993 and 1994 of $8,863 and $2,766, respectively. Respondent also determined deficiencies in the Federal income tax of petitioner John H. Lovejoy (Mr. Lovejoy) for the taxable years 1993 and 1994 of $12,018 and $5,905, respectively. These cases have been consolidated for purposes of trial, briefing, and opinion because they involve common questions ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011