Ricky C. Hutchinson and Tammy L. McNichol - Page 6

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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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