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U.S. Citizens Abroad); Adler v. Commissioner, 330 F.2d 91, 93
(9th Cir. 1964), affg. T.C. Memo. 1963-196 (Your Federal Income
Tax for Individuals). The authoritative sources of Federal tax
law are the statutes, regulations, and judicial decisions; they
do not include informal IRS publications. See Zimmerman v.
Commissioner, 71 T.C. 367, 371 (1978), affd. 614 F.2d 1294 (2d
Cir. l979).
Section 152(e)(2) clearly requires that the custodial parent
release the dependency exemption for a child by signing a written
declaration to that effect in order for the noncustodial parent
to claim the child’s dependency exemption. The control over a
child’s dependency exemption conferred on the custodial parent by
section 152(e)(2) was intended by Congress to simplify the
process of determining who is entitled to claim dependency
exemptions for children of a marriage. See H. Rept. 98-432 (Part
2), at 1498 (1984). To make section 152(e)(2) work as intended,
that control must be preserved by insisting on adherence to the
requirements of section 152(e)(2). Simply attaching a State
court order that is not signed by the custodial parent to the
return of the noncustodial parent does not satisfy the express
statutory requirements of section 152(e)(2)(A). Although the
Permanent Orders granted Mr. Lovejoy the right to claim the
dependency exemptions for his children, a State court cannot
determine issues of Federal tax law. See Kenfield v. United
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