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disagree, contending that, in order for a document to qualify
under section 152(e)(2), the custodial parent must sign it.
Although the Permanent Orders gave Mr. Lovejoy the right to claim
the dependency exemptions, Mr. Lovejoy still had to satisfy the
requirements of section 152(e)(2). According to Ms. Miller and
respondent, Mr. Lovejoy failed to do so. We agree.
This Court consistently has held that section 152(e)(2)
clearly and unambiguously requires the custodial parent to sign a
written declaration releasing the dependency exemption for his or
her child to the noncustodial parent. See Neal v. Commissioner,
T.C. Memo. 1999-97; Paulson v. Commissioner, T.C. Memo. 1996-560;
White v. Commissioner, T.C. Memo. 1996-438; Peck v. Commissioner,
T.C. Memo. 1996-33. On several occasions we have rejected well-
intentioned but flawed attempts to comply with section 152(e)(2).
See Neal v. Commissioner, supra; Paulson v. Commissioner, supra;
White v. Commissioner, supra; Peck v. Commissioner, supra. Even
where a State court judge has entered an order “granting” the
noncustodial parent the right to claim the Federal dependency
exemption for his child and the noncustodial parent attached a
copy of the order to his tax return, we have rejected the
noncustodial parent’s claim to the dependency exemption where the
custodial parent failed to sign a written declaration as required
by section 152(e). See Neal v. Commissioner, supra.
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