John W. and Faythe A. Miller - Page 3

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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                                    

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Last modified: May 25, 2011