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exemptions for corresponding taxable years regardless of
provisions of divorce decree).
Although we are sympathetic with petitioners’ plight, “we
are bound by the wording of the statute as enacted and the
accompanying regulations, when consistent therewith.” Michaels
v. Commissioner, 87 T.C. 1412, 1417 (1986). The language of
section 152(e), as manifested through its accompanying
regulations, is unambiguous. It grants the dependency exemption
to a noncustodial parent only where he or she attaches a valid
Form 8332 or its equivalent to a Federal income tax return for
the taxable year in which he or she claims the exemption.
Congress added this written declaration requirement to section
152(e) in 1984 to provide more certainty to the “often subjective
and * * * difficult problems of proof and substantiation” that
accompanied dependency exemption disputes under the prior
statute. H. Rept. 98-432 (Part 2), at 1498 (1984). Congress
sought clarity as to which of two divorced parents would receive
the dependency exemption for a taxable year and accomplished it
by conditioning the noncustodial parent’s claim upon the written
verification of the custodial parent’s release of his or her
claim. To preserve Congress’s goal we must insist on strict
adherence to the requirements of section 152. Miller v.
Commissioner, supra at 196; Bramante v. Commissioner, T.C. Memo.
2002-228. Accordingly, we sustain respondent’s disallowance of
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