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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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