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substance of that form. Id.; Miller v. Commissioner, 114 T.C.
184, 189 (2000). “The exemption may be released for a single
year, for a number of specified years (for example, alternate
years), or for all future years, as specified in the
declaration.” Sec. 1.152-4T(a), Q&A-4, Temporary Income Tax
Regs., 49 Fed. Reg. 34459 (Aug. 31, 1984).
In the present case, Ms. Allison, as the custodial parent,
did not sign Form 8332 or any written declaration or statement
agreeing not to claim exemptions for any of the five children,
and no such form, declaration, or statement was attached to
petitioner’s return for the year in issue. It follows,
therefore, that the exception set forth in section 152(e)(2) does
not apply and that the general rule of section 152(e)(1) does
apply. Accordingly, petitioner is not entitled to deductions for
dependency exemptions for any of his five children for 1998.
Sec. 152(e)(1); Miller v. Commissioner, supra.
In view of the foregoing, we sustain respondent’s
determination on this issue.
B. Child Tax Credit and Additional Child Tax Credit
Section 24(a) authorizes a child tax credit with respect to
each “qualifying child” of the taxpayer. Section 24(d)
authorizes an additional child tax credit for families with three
or more “qualifying” children.
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