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" ... In the present case, the noncustodial parent attached Form 8332 to his ——— return. Although Part I was not completed, Part II was and the “all future years” language used in Part II of the form covers the ——— taxable year. Accordingly, under § 152(e), the two children are treated as qualifying children or qualifying relatives of the Father, the noncustodial parent. Regarding the custodial parent's claim that she did not execute the Form 8332 attached to the non-custodial parent's tax return, if the form is completed, signed, and attached to the noncustodial parent's return, the IRS should allow the dependency exemption for the children named on the form to the noncustodial parent and deny the custodial parent's claim to the dependency exemption. If the custodial parent did not execute the Form 8332, her remedy is against the noncustodial parent. In addition, if the custodial parent did release the dependency exemption for all future years, the regulations under § 152 allow her to revoke the release for the first calendar year after the year in which she revokes the release. Part III of Form 8332 is used for future year revocations. (Emphasis added) ... "