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The declaration required under section 152(e)(2) must be made
either on a completed Form 8332 or on a statement conforming to
the substance of Form 8332. See sec. 1.152-4T(a), Q&A-3,
Temporary Income Tax Regs., supra. The exemption may be released
for a single year, for a number of specified years, or for all
future years "as specified in the declaration." Sec. 1.152-
4T(a), Q&A-4, Temporary Income Tax Regs., supra.
In this case, Mr. Lovejoy, the noncustodial parent, claimed
the dependency exemptions for his minor children for each of the
years at issue pursuant to a provision in the Permanent Orders
which summarily stated that Mr. Lovejoy "shall claim both of
[his] children on his tax returns as exemptions." At trial, Mr.
Lovejoy testified that, although he did not ask Ms. Miller, the
custodial parent, to complete or sign Form 8332, he did attach a
copy of portions of the Permanent Orders to each of his returns
for 1993 and 1994 prior to filing the returns.7
7The copies of Mr. Lovejoy's 1993 and 1994 returns, which
were admitted into evidence as exhibits to the stipulation of
facts, did not include any part of the Permanent Orders as
attachments. Mr. Lovejoy explained this omission by pointing out
that the stipulations were negotiated and agreed upon before any
issue regarding the dependency exemptions was raised and that
someone in the Service Center could have removed the attachments.
In her opening statement, respondent's counsel acknowledged this
was possible. We also note that the returns in evidence were
incomplete in other ways. For example, the 1994 return was filed
electronically. Although what purports to be the 1994 return in
the record summarizes the information included on the
electronically filed return, there is no signature page. In
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