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children as dependents only if one of the three statutory
exceptions in section 152(e) is met. Under these exceptions, the
"noncustodial parent" is treated as providing over half of a
child's support if: (1) Pursuant to section 152(e)(2), the
custodial parent signs a written declaration that the custodial
parent will not claim the child as a dependent, and the
noncustodial parent attaches the written declaration to the
noncustodial parent's return for the taxable year; (2) pursuant
to section 152(e)(3), there is a multiple-support agreement
between the parties as provided in section 152(c); or (3)
pursuant to section 152(e)(4), there is a qualified pre-1985
instrument providing that the noncustodial parent shall be
entitled to any deduction allowable under section 151 for the
child, provided that certain other requisites, not pertinent
here, are met.
There is no evidence that any of the exceptions applies to
this case. Petitioner's former wife did not release her claim to
the exemptions. For 2000, she did not sign a Form 8332, Release
of Claim to Exemption for Child of Divorced or Separated Parents,
or any similar statement substantially in the form of a Form
8332, to release to petitioner her right to claim deductions for
certain dependency exemptions. Petitioner did not attach a Form
8332 or anything substantially similar to a Federal income tax
return for 2000. See Miller v. Commissioner, supra.
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