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number will not be issued an IRS individual taxpayer
identification number.” Sec. 301.6109-1(d)(4), Proced. & Admin.
Regs.2
SSN’s are issued by the Social Security Administration of
the U.S. Department of Health and Human Services (the SSA) upon
application by a citizen, qualified alien, or by a parent on
behalf of a qualified child. See generally 20 C.F.R. secs.
422.101 to 422.112 (2000). The issuance of an SSN entails
several consequences, including (i) the creation of a record at
the SSA of that person’s earnings for purposes of determining the
old-age and other benefits to which the person may be entitled,
and (ii) establishing a unique numerical identifier for the
individual for use by a variety of governmental and private
entities.3 When the SSN was first chosen as the identification
2Sec. 301.6109-1(d)(4), Proced. & Admin. Regs., was added to
the regulations by T.D. 8671, 1996-1 C.B. 314, and is effective
for any return, statement, or other document required to be filed
after Dec. 31, 1995. Previously, respondent had issued ITIN’s to
taxpayers who claimed religious objections to the use of SSN’s.
See Wolfrum v. Commissioner, T.C. Memo. 1991-370, affd. 972 F.2d
350 (6th Cir. 1992).
3In addition to tax administration, SSN’s are used by
Federal and State Governments to administer public assistance
programs, veteran’s benefits, driver’s licences, motor vehicle
registrations, Federal student grants and loans, child support
obligations, the Selective Service System, blood donations, and
jury selection. SSN’s are also commonly used in the private
sector by credit bureaus, banks, schools, and medical
recordkeepers. See Komuves, “We’ve Got Your Number: An Overview
of Legislation and Decisions to Control the Use of Social
Security Numbers as Personal Identifiers”, 16 J. Marshall J.
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