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signed by petitioner, which appears to satisfy the above
requirements and includes, on the signature lines of both Parts I
and II, a signature that purports to be that of petitioner Tammy
L. McNichol. Petitioner, however, contends that she released the
dependency exemptions for only the year 1992 and did not release
or did not intend to release the exemptions for any years
subsequent to 1992. She denies having consented to Part II,
releasing the exemptions for all “future” years. Prior to trial,
petitioner and her former spouse each engaged the services of
forensic experts to address whether petitioner Tammy L. McNichol
signed Form 8332 to allow Mr. McNichol to claim the dependency
exemption deductions for all “future” years. The reports of the
forensics experts were not offered at trial, nor were the experts
called as witnesses. However, the parties stipulated that both
evaluations provided inconclusive results.3
The Court considers the testimony of Mr. McNichol as pivotal
in the decision of this case. Mr. McNichol had engaged the
services of an income tax return preparer to prepare his 1992
Federal income tax return. The return preparer (who did not
3
Although not entirely clear, it does not appear that
respondent engaged the services of a forensic expert. Although
counsel for respondent referred to “both parties” as having
employed the forensic experts, the Court assumes that “both
parties” meant petitioner and her former spouse, Mr. McNichol.
Neither petitioner, Mr. McNichol, nor respondent addressed the
forensic evaluations at trial.
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