Sherald Lynn and Susan Jana Davis - Page 7




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          Government has a compelling interest in effectively tracking                
          claimed dependency exemptions.).  Instead, petitioners contend              
          that requiring them to use SSN’s for their children is not the              
          least restrictive means of meeting the Government’s compelling              
          interests.  Petitioners further contend that issuing their                  
          children IRS individual taxpayer identification numbers (ITIN) is           
          a less restrictive means of meeting respondent’s compelling                 
          interest than requiring SSN’s.                                              
               Petitioners’ argument is substantially the same as the                 
          argument recently raised in Miller v. Commissioner, supra.  In              
          Miller, the taxpayers believed that SSN’s are universal numerical           
          identifiers that were equated with the “mark of the Beast” warned           
          against in the Bible at Revelation 13:16-17.  In that case, the             
          taxpayers’ religious objections extended only to unique numerical           
          identifiers and not to numbers issued for discrete purposes.                
          Accordingly, the taxpayers offered to obtain ITIN’s for their               
          children and provide the ITIN’s on their return.  In Miller, we             
          rejected this argument.  In so doing, we found that issuing                 
          ITIN’s to such individuals, who were otherwise eligible to                  
          receive an SSN, would be less effective in detecting fraud than             
          requiring the use of SSN’s.                                                 
               SSN’s are unique numerical identifiers that are used to                
          ferret out fraudulent applications through the use of computer              








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