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Going only from my VITA training as well (first day of volunteering today!) I have to agree with Patzer that it may very well fly.

Here's the wording from Publication 17 (emphasis mine):
Written declaration. The custodial parent may use either Form 8332 or a similar statement (containing the same information required by the form) to make the written declaration to release the exemption to the noncustodial parent. The noncustodial parent must attach the form or statement to his or her tax return.

Also from Pub 17:
Parents who never married. This special rule for divorced or separated parents also applies to parents who never married.

So it seems to me that if the form included does have all the information required on Form 8332, it would be acceptable. That information appears to include SS# of both parents, child's name, year (in this case, even years), and the signature of the custodial parent, then you'd probably be okay. Including the proof of meeting the requirement couldn't hurt.

If Phil, Peter, or Ira wish still wish to disagree, I would take their word stronger than mine, that's for sure. But by the wording of the IRS, if you have a 8332 substitute, that should be okay. And it seems to make no difference whether they are divorced or never married.
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