- 8 -
matching techniques. See Bowen v. Roy, 476 U.S. 693, 710 (1986).
Through cross-matching of SSN’s, respondent can detect erroneous
or fraudulent claims by identifying whether an SSN has been
claimed on another return for the year. See Miller v.
Commissioner, supra at ___ (slip op. at 9-10). Congress
acknowledged this benefit in 1994, when it eliminated an
exception to the TIN requirement. See sec. 6109 as amended by
Uruguay Round Agreements, Pub. L. 103-465, sec. 742, 108 Stat.
5010 (1994). The House report discussing this section states:
The requirement that TIN’s be provided with respect
to each dependent claimed on a tax return has signi-
ficantly reduced the improper claiming of dependents.
Requiring that TIN’s be supplied regardless of the age
of the dependent will further reduce the improper
claiming of dependents. [H. Rept. 103-826, 196
(discussing section 742(b) of the Uruguay Round
Agreements Act, Pub. L. 103-465, 108 Stat. 4809, 5010
(1994)).]
Issuing an ITIN to an individual who is otherwise eligible
to receive an SSN creates the risk that the individual could
subsequently obtain an SSN. See Miller v. Commissioner, supra at
___ (slip op. at 12-13). In such cases, the individual would
have two TIN’s, each purporting to be a unique identifier. See
id. If an individual were to have two TIN’s, respondent’s cross-
matching program would be less effective in revealing duplicate
claims than if the individual had only one identifying number.
See Miller v. Commissioner, supra; U.S. General Accounting
Office, Tax Administration Could Do More to Verify Taxpayer
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011