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agreement, Rockwell v. Rockwell, 681 A.2d 1017 (Del. 1996); Solis
v. Tea, 468 A.2d 1276 (Del. 1983). Respondent has not argued,
and nothing in the record indicates, that the separation
agreement was invalid in any respect.
Second, we find that the separation agreement conforms to
the substance of Form 8332. The agreement provided that
petitioner was unconditionally entitled to the dependency
exemption for Brandi, and it was signed and dated by Ms. Rogers,
Brandi’s custodial parent. The language of the agreement, which
referred to the separate returns of petitioner and Ms. Rogers as
well as to joint returns to be filed no later than 1991,
indicates that the allocation of the dependency exemption
deductions was to apply to all returns filed after the divorce
had been finalized. Thus, although the agreement did not
explicitly state each and every taxable year to which it was to
apply, we find that it unambiguously stated that it was to apply
to all future years, which is permissible pursuant to section
1.152-4T(a) Q&A-4, Temporary Income Tax Regs., 49 Fed. Reg. 34459
(Aug. 31, 1984). We note that, in the notice of deficiency,
respondent did not challenge the language of the agreement but
questioned only whether the agreement had been incorporated into
a divorce decree: The notice stated that the “separation
agreement did contain a provision entitling you to claim Brandi
as a dependent exemption on your tax return with no conditions
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