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requirements of section 274(d), and we, therefore, sustain
respondent’s determination for the taxable years in issue.
Issue 3. Whether Petitioner Is Entitled To Claim Additional
Exemptions for His Spouse and Her Two Daughters for Taxable Years
1993 Through 1995
1993
In 1993, petitioner was engaged to be married to the woman
who would become his wife in May 1994. Because of the support he
purportedly provided to his fiancee and her two daughters,
petitioner claims that he is entitled to additional dependency
exemptions in 1993. Respondent did not allow additional
dependency exemptions for petitioner's fiancee and her daughters.
Section 151(c) allows a taxpayer, subject to certain
requirements, a deduction for a personal exemption for each of
the taxpayer’s dependents as defined in section 152. A dependent
is defined as an individual over half of whose total support is
received from the taxpayer, and who must either be related to the
taxpayer in one of the ways enumerated in section 152(a)(1)
through (8) or be a member of the taxpayer’s household within the
meaning of section 152(a)(9). See sec. 152(a).
In 1993, petitioner was not related to his fiancee or her
two daughters by blood or marriage, nor was he their adoptive or
foster father. Accordingly, to claim his fiancee and her
daughters as dependents in 1993, petitioner must establish, inter
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