The National Association of Enrolled Agents has submitted a letter to IRS Commissioner Everson concerning the definition of a dependent in §152.  Here is the opening:

As president of the National Association of Enrolled Agents (NAEA), I write on behalf of approximately 40,000 enrolled agents (EAs) nationwide. The purpose of this letter is to share with you our concern with the ambiguity and interpretation of a recently-passed law. Section 201 of the Working Families Tax Relief Act of 2004 revises the §152 definition of a dependent.

§152, titled Dependent Defined, is creating a good deal of controversy in the practitioner community. A literal interpretation of that section appears to lead to unintended consequences in determining the dependency status of some individuals. Enrolled agents would like the Service to consider some of the stranger applications of such an interpretation and request guidance so practitioners can correctly carry out the intent of Congress in creating the two categories of dependents: qualifying child and qualifying relative.

(Hat Tip:  Jay Wiedwald.)