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have been in the physical custody of each parent for exactly half
of each of the years at issue, and not in the custody of
petitioner for a greater portion of either year.
Petitioner presented no corroborative evidence showing that
he maintained physical custody of Adam and Jordan for a greater
portion of the 1997 or 1998 calendar years than did Ms.
Brittingham. In fact, petitioner’s own testimony indicates that
Adam and Jordan were in the physical custody of Ms. Brittingham
for a greater portion of time in each of the years at issue.
Petitioner has failed to establish that he has met the custody
requirement under section 152(e), and, accordingly, he is not
treated as having provided over half the support of Adam and
Jordan in each of the years at issue.
Petitioner’s claim that he is entitled to the dependency
exemption deductions because of the advice of an IRS employee is
without merit. This Court has previously held that the
authoritative sources of Federal tax law are statutes,
regulations, and judicial case law and not informal IRS sources.
Zimmerman v. Commissioner, 71 T.C. 367, 371 (1978), affd. without
published opinion 614 F.2d 1294 (2d Cir. 1979); Green v.
Commissioner, 59 T.C. 456, 458 (1972). Additionally, in order to
ensure uniform enforcement of the tax law, the Commissioner must
follow authoritative sources of Federal tax law and may correct
mistakes of law made by IRS agents or employees. Dixon v. United
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