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conform to the substance of Form 8332 in part because it failed
to include the years for which the exemption claims would be
released and the Social Security numbers of either parent);
Cafarelli v. Commissioner, T.C. Memo. 1994-265 (holding that the
Form 8332 was not an effective release of the custodial parent’s
dependency exemption in part because the noncustodial parent did
not specify the year for which the exemption claims would be
released).
The copy of the last page of the divorce decree that the
Dundas attached to their 1998 return plainly is not an effective
release of Cramer’s claim to dependency exemption deductions for
1998.
Dunda contends that he relied on a publication provided by
the Internal Revenue Service indicating that Form 8332 was
unnecessary and that the copy of the divorce decree granting him
the right to claim the dependency exemption deductions was
sufficient. Well-established precedent, however, states that
taxpayers rely on such publications at their peril. Miller v.
Commissioner, supra at 195. Administrative guidance contained in
IRS publications is not binding on the Government, nor can it
change the plain meaning of the tax statutes. Id. (citing
Johnson v. Commissioner, 620 F.2d 153, 155 (7th Cir. 1980), affg.
T.C. Memo. 1978-426; Adler v. Commissioner, 330 F.2d 91, 93 (9th
Cir. 1964), affg. T.C. Memo. 1963-196)). The authoritative
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