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their religious objection to the use of identifying numbers for
their children.
Petitioners believe that SSN’s are universal numerical
identifiers to be equated with the “mark of the Beast” warned
against in the Bible at Revelation 13:16-17. Petitioners both
have SSN’s and used them on their 1996 tax return but wish to
avoid obtaining SSN’s for their children.
Petitioners’ religious objections extend only to universal
identifiers and not to numbers issued for a discrete purpose.
Accordingly, petitioners have offered to obtain Individual
Taxpayer Identification Numbers (ITIN’s) for their children and
provide the ITIN’s on their return. Respondent, however, refuses
to issue ITIN’s to petitioners’ children because respondent takes
the position that Treasury regulations permit issuance of ITIN’s
only to those who are ineligible to receive SSN’s.
Except for the requirement that petitioners include their
children’s SSN’s on their return, petitioners have met all the
statutory requirements for claiming dependency exemptions in
1996. Respondent concedes that petitioners have a sincerely held
religious belief which opposes the use of SSN’s for their minor
children, but respondent denies that he is required to
accommodate that belief in administering the dependency
exemption.
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Last modified: May 25, 2011