- 5 -
ineligible for SSN’s. Thus, under section 151(e) and the
applicable regulations, petitioners cannot properly claim
dependency exemption deductions for their children unless they
provide SSN’s for them. Deductions are strictly a matter of
legislative grace, and taxpayers must satisfy the specific
requirements for any deduction claimed. See INDOPCO, Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v.
Helvering, 292 U.S. 435, 440 (1934).
Petitioners, however, ask the Court to find that section
151(e) is “invalid because of its obvious coercive and irrelevant
nature” or to require the IRS to issue individual taxpayer
identification numbers for their children. They are opposed to
having SSN’s assigned to their children because they
conscientiously object to obligating their children “to an
irrevocable contract” and “believe it is not right to indenture
minors for life.”
We recently held that the SSN requirement is the least
restrictive means of achieving the Government’s compelling
interests in implementing the Federal tax system in a uniform,
mandatory way and in detecting fraudulent claims to dependency
exemptions. See Miller v. Commissioner, 114 T.C. __ (2000);
Davis v. Commissioner, T.C. Memo. 2000-210. In Miller and in
Davis, the taxpayers raised religious objections to the use of
SSN’s. We explicitly rejected the taxpayers’ suggestion that the
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011