Norman W. Brissett - Page 7

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          Security number of the parent claiming the exemption.  Id. at               
          190.                                                                        
               In the present case, petitioner and Ms. Brissett have joint            
          legal and physical custody of Jacquelynne and Dominic under the             
          terms of the separation agreement.  However, for purposes of                
          section 152(e), the parent having custody for a greater portion             
          of the calendar year–-Ms. Brissett in this case--is deemed to be            
          the custodial parent.  Petitioner, as the noncustodial parent for           
          purposes of section 152(e), was not entitled to the claimed                 
          dependency exemptions unless he complied with the provisions of             
          section 152(e)(2) and the regulations thereunder by attaching to            
          his return a written declaration or Form 8332 executed by Ms.               
          Brissett.  Petitioner did not attach such a declaration or Form             
          8332 to his return, and accordingly, he is not entitled to the              
          deduction for dependency exemptions for Jacquelynne and Dominic             
          for the 2000 taxable year.                                                  
               Petitioner nevertheless argues that he is current in his               
          child support obligation and that, under the terms of the                   
          separation agreement, he is entitled to the deduction for                   
          dependency exemptions.  We are not unsympathetic to petitioner’s            
          position.  However, we are bound by the language of the statute             
          as it is written and the accompanying regulations, when                     
          consistent therewith.  Michaels v. Commissioner, 87 T.C. 1412,              
          1417 (1986).  The Internal Revenue Code is clear as to the                  






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