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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.
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