Prior to the Tax Reform Act of 1984, the Internal Revenue Code specified the conditions under which a parent could claim a child as an income tax deduction. For example, a noncustodial parent could claim the deduction when the trial court order awarded it to him or her. However, the conditions were difficult to apply, and parents frequently contested the deduction issue with the Internal Revenue Service. See Joseph L. Landenwich, Divorce and Amended Section 152(e) of the Internal Revenue Code: Do State Courts Have the Power to Allocate Dependency Exemptions ?, 29 J. Fam. L. 901, 908 (1990/1991) (citing Cross v. Cross, 178 W. Va. 563, 363 S.E.2d 449, 457 (W. Va. 1987); Fudenberg v. Molstad, 390 N.W.2d 19, 21 (Minn. Ct. App. 1986)). The Tax Reform Act of 1984 created a presumption that the custodial parent would enjoy the benefit of the deduction unless the parents entered into a multiple support agreement or the custodial parent released the exemption to the noncustodial parent. See I.R.C. 152(e)(2)(b) (1982).