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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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Last modified: May 25, 2011