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attach a completed Form 8332 to his 1998 tax return, but he also
testified that he believed Cramer would have refused to sign a
Form 8332. Cramer’s direct testimony that she “wouldn’t have
signed” confirmed that she had no intention of releasing the
dependency exemptions for 1998.2 The Cramers’ return, on which
Cramer claimed the dependency exemptions for Charles and Daniel
for 1998, further confirms that she did not intend to release the
dependency exemptions for that year.
Moreover, the last page of the divorce decree fails to
specify the names of the children for which the exemption claims
would be released, the year for which the exemption claims would
be released, and Cramer’s Social Security number. See Miller v.
Commissioner, supra at 190; see also Loffer v. Commissioner,
supra; Horn v. Commissioner, supra (holding that a handwritten
note did not conform to the substance of Form 8332 in part
because the note failed to identify the specific years to which
it was meant to apply); White v. Commissioner, T.C. Memo. 1996-
438 (holding that a letter purporting to release the dependency
exemptions and signed by the custodial parent taxpayer did not
2 Cramer contends that, pursuant to the child support
order, Dunda is not entitled to the exemption deductions because
Dunda allegedly was in arrears on his child support payments. We
do not address the question whether Dunda was precluded from
claiming the dependency exemptions because his child support
payments were in arrears. Cramer’s testimony, regardless of the
validity of her contention, clearly indicates that she had no
intention of releasing the dependency exemptions to Dunda in
1998.
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