- 6 - Commissioner could accommodate their religious beliefs by issuing individual taxpayer identification numbers for their children because it would be a less effective means of detecting fraud than requiring SSN’s. See Miller v. Commissioner, supra; Davis v. Commissioner, supra. We do not question the sincerity of petitioners’ objections to obtaining SSN’s for their children. Petitioners, however, are not entitled to the benefit of dependency exemption deductions afforded by section 151 unless they obtain the SSN’s clearly required by section 151(e). See Miller v. Commissioner, supra; Davis v. Commissioner, supra. Accordingly, we uphold respondent’s determination that petitioners are not entitled to dependency exemption deductions for their 10 children. Respondent has conceded that if petitioners are not entitled to dependency exemption deductions, they are not liable for the alternative minimum tax. We therefore turn our attention to petitioners’ liability for an addition to tax under section 6662(a). Section 6662(a) imposes a penalty of 20 percent of the portion of an underpayment attributable to negligence or disregard of rules or regulations or attributable to any substantial understatement of income tax. See sec. 6662(b)(1) and (2). “Negligence” is defined as any failure to make a reasonable attempt to comply with the provisions of the InternalPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011