- 8 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007