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The issues for decision are: (1) Whether requiring
petitioners to provide Social Security numbers for their children
as a condition to allowing them dependency exemptions for their
children violates the Religious Freedom Restoration Act of 1993;
(2) whether requiring petitioners to provide Social Security
numbers for their children as a condition to allowing them
dependency exemptions for their children violates the Privacy Act
of 1974.
The facts have been fully stipulated under Rule 122 and are
so found. Petitioners resided in Liberty County, Texas, when the
petition in this case was filed.
Petitioners claimed dependency exemptions for their eight
children on their 1996 Federal income tax return. However,
petitioners failed to provide the children’s Social Security
numbers on this tax return. At respondent’s request, petitioners
provided the children’s birth certificates, immunization charts,
and medical identification cards.
Respondent concedes that petitioners have met all the
statutory requirements for claiming dependency exemptions for
their children for 1996, except for the requirement that
petitioners include their children’s Social Security numbers on
their return. Accordingly, pursuant to section 151(e) respondent
disallowed petitioners’ claimed dependency exemptions for the
children.
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Last modified: May 25, 2011