J. Erik and Carris J. Kocher - Page 6




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          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 Internal              






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