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1040A a handwritten note, dated February 23, 1999, which stated
as follows:
To Whom it may Concern,
As in the previous years, my ex-spouse Rochelle
(Shellie) Jane Horn refuses to sign Form 8332 stating
it would “mess up” her ability to receive financial
[aid] for her schooling.
Sincerely,
Steven D. Horn
In the notice of deficiency, respondent disallowed
petitioner’s claimed exemption deductions for the children on the
grounds that petitioner had failed to verify his entitlement
thereto.
Discussion
A taxpayer generally may deduct an exemption amount for each
dependent child under 19 years of age. Sec. 151(c)(1)(B)(i). To
be entitled to claim a child as a dependent, the taxpayer
generally must provide over half the child’s support. Sec.
152(a). If the child’s parents are divorced or separated, the
child will generally be treated as receiving over half of his
support from the custodial parent; i.e., the parent having
custody for a greater portion of the calendar year. Sec.
152(e)(1). As an exception to this general rule, the
noncustodial parent is treated as providing over half the support
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