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34451 (Aug. 31, 1984). The declaration required must be made on
a form provided by the Internal Revenue Service (Form 8332) or on
a statement that “[conforms] to the substance of such form.” Id.
In Miller v. Commissioner, 114 T.C. 184 (2000), we
recognized that an alternative to Form 8332 may be used by the
noncustodial parent to substantiate his right to claim a
dependency exemption for his child. Any alternative
must contain substantially the same information required by
Form 8332. In particular, the document must satisfy the
signature requirement of section 152(e)(2). The signature
of the custodial parent is critical to the successful
implementation of Congress’ plan to eliminate support-based
disputes regarding dependency exemptions and to simplify the
rules regarding when a noncustodial parent may claim the
dependency exemptions for his or her children. [Id. at 191-
192.]
We rejected the argument in Miller that a court decree, even if
executed by the former spouse, satisfied the requirements of
section 152(e)(2). In this case, petitioner is the noncustodial
parent. The Decree required petitioner’s former wife to execute
the statement required; she, however, refused to do so. While we
are sympathetic to petitioner’s plight, we note that petitioner’s
remedy lies with the Arizona divorce court. It is not within
this Court to enforce that decree. We recognize that, as
petitioner points out, enforcing the Decree may involve an
expenditure of funds, but that is a decision that petitioner must
make. Petitioner has not chosen that route, and he is not
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