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citizen, national, or resident of the United States, over half of
whose support is received from the taxpayer. See sec. 152(a) and
(b)(3). In order to qualify as a dependent, an individual must
also be related to the taxpayer in one of the ways enumerated in
section 152(a)(1) through (8), or be an unrelated individual who
lives with the taxpayer and is a member of the taxpayer’s
household throughout the entire taxable year of the taxpayer.
See sec. 152(a)(9); Trowbridge v. Commissioner, 268 F.2d 208 (9th
Cir. 1959), affg. 30 T.C. 879 (1958); McMillan v. Commissioner,
31 T.C. 1143, 1145-1146 (1959); Turay v. Commissioner, T.C. Memo.
1999-315, affd. per order (D.C. Cir., May 23, 2000); sec. 1.152-
1(b), Income Tax Regs.
In the present case, petitioner claimed dependency exemption
deductions with respect to four individuals during the years in
issue. Of these four, only Jaleshia was related to petitioner as
his daughter. See sec. 152(a)(1). For the remaining three
individuals who were not related to petitioner, Ms. Pressley and
Tyra did not live with petitioner during the entire taxable year
of 1999, and Ms. Stackhouse did not live with petitioner during
the entire taxable year of 2000. Accordingly, they do not
qualify as dependents within the meaning of section 152(a)(9).
Section 152(e)(1) provides a special support test in which
the custodial parent is entitled to the dependency exemption
deduction “if a child (as defined in section 151(c)(3)) receives
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