Michael R. Loffer - Page 4




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          exemption is claimed.  Secs. 151(c)(1), 152(a).  Where parents              
          are divorced or separated, the parent who has physical custody of           
          a child for the greater portion of a calendar year (the                     
          “custodial parent”) generally is deemed to provide more than half           
          of such child’s support in that year.  Sec. 152(e).                         
               A custodial parent, however, may release the right to a                
          dependency exemption with respect to a child by declaring in a              
          written statement that he or she will not claim the child as a              
          dependent for a particular year.  Sec. 152(e)(2)(A).  If the                
          custodial parent releases his or her right to a dependency                  
          exemption with respect to a child, the noncustodial parent may              
          claim the dependency exemption for that child provided the                  
          noncustodial parent attaches the custodial parent’s written                 
          release statement to the noncustodial parent’s tax return.  Sec.            
          152(e)(2)(B).                                                               
               Under section 152(e)(2), respondent issued Form 8332                   
          (Release of Claim to Exemption for Child of Divorced or Separated           
          Parents) for taxpayers to use to satisfy the written declaration            
          requirement of section 152(e)(2).  Using Form 8332, the custodial           
          parent is to provide the following:  (1) The name of the child              
          with respect to which an exemption is released; (2) the year for            
          which the exemption is released to the noncustodial parent;                 
          (3) signature, date of signature, and Social Security number of             
          the custodial parent; and (4) the name and Social Security number           






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