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resolved without the involvement of the Internal Revenue
Service.” Id. at 1499.
In this case, petitioner executed the Form 8332, the
consequences of which she now attempts to avoid. If we were to
relieve her of those consequences under these circumstances, we
essentially would have to ignore the language of the statute, the
regulations, and the legislative history. The result is to
permit the whipsaw that Congress sought to prevent. For section
152(e) to operate as intended by Congress, strict adherence to
the literal requirements of section 152(e) must be observed. See
Miller v. Commissioner, supra at 196; Cafarelli v. Commissioner,
T.C. Memo 1994-265. We will not ignore the Form 8332 here.
Petitioner executed the form, and she is bound by its terms with
regard to the year before the Court.
2. Child Tax Credit
Section 24(a) provides that a taxpayer may claim a credit
for “each qualifying child”. A qualifying child is defined,
inter alia, as any individual if “the taxpayer is allowed a
deduction under section 151 with respect to such individual for
the taxable year”. Sec. 24(c)(1)(A). For the reasons stated
above, petitioner may not claim dependency exemption deductions
for the children under section 151, and, therefore, she may not
claim a child tax credit.
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