- 6 - exemptions, or otherwise conform to the substance of Form 8332, as required by the applicable regulations. Sec. 152(e)(2)(A); Horn v. Commissioner, T.C. Memo. 2002-290; Cafarelli v. Commissioner, T.C. Memo. 1994-265; White v. Commissioner, T.C. Memo. 1996-438. In fact, Ms. Burke claimed the three exemptions for her children on her 1999 income tax return. We also note that the statement does not conform with Form 8332 because it does not expressly set forth the name of each of the three children, although Kathryn is mentioned in another provision, and because it does not specify the year, years, or all future years. Miller v. Commissioner, 114 T.C. 184, 191-192 (2000). Lastly, the statement is not an unrestricted release of the exemptions to petitioner because it is conditioned on a support test. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011