John W. and Faythe A. Miller - Page 5

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            number will not be issued an IRS individual taxpayer                                       
            identification number.”  Sec. 301.6109-1(d)(4), Proced. & Admin.                           
                  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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