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Form 8332, Release of Claim to Exemption for Child of Divorced or
Separated Parents, requires the (1) name of the children for
which exemption claims were released, (2) years for which the
claims were released, (3) signature of the custodial parent, (4)
Social Security number of the custodial parent, (5) date of
signature, and (6) name and Social Security number of the parent
claiming the exemption.
In this case, Mr. Crowell attached to his 1998 and 1999
Federal income tax returns a Form 8332 signed by Mrs. Crowell
with respect to the dependency exemption deductions for their
children. Part I of that form, Release of Claim to Exemption for
Current Year, allows Mr. Crowell the dependency exemptions for
Cody, David, Ben, Beth, and Adam for the year 1995. Part II of
that form, Release of Claim to Exemption for Future Years, allows
Mr. Crowell dependency exemption deductions for Cody, David, Ben,
and Beth for 11 years, 1996 through 2006. Both Parts I and II of
the form are dated August 2, 1996. Respondent, in the notice of
deficiency to Mr. Crowell, disregarded without explanation the
Form 8332 and disallowed the dependency exemption deductions
claimed for the four children for 1998 and 1999. Respondent
likewise disallowed the four dependency exemption deductions for
3(...continued)
Corp. v. Commissioner, 751 F.2d 123, 127 (2d Cir. 1984), revg. on
other grounds T.C. Memo. 1984-145.
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