John W. and Faythe A. Miller - Page 10

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            thereby detecting erroneous or fraudulent claims.  For example,                            
            SSN’s make it easier for the IRS to determine whether divorced                             
            parents are both trying to claim their children as dependents.                             
            Congress acknowledged this benefit in 1994, when it eliminated an                          
            exception to the TIN requirement for dependents below a certain                            
                  The requirement that TIN’s be provided with respect to each                          
                  dependent claimed on a tax return has significantly reduced                          
                  the improper claiming of dependents.  Requiring that TIN’s                           
                  be supplied regardless of the age of the dependent will                              
                  further reduce the improper claiming of dependents.  [H.                             
                  Rept. 103-826, at 196 (1994) (discussing sec. 742(b) of the                          
                  Uruguay Round Agreements Act, Pub. L. 103-465, 108 Stat.                             
                  4809, 5010 (1994)).]                                                                 
            The use of SSN’s also helps ensure that there is indeed a person                           
            in existence to support the claimed exemption.  See U.S. General                           
            Accounting Office, Tax Administration IRS Could Do More to Verify                          
            Taxpayer Identities (Pub. No. GAO/GGD 95-148) (Aug. 30, 1995)                              
            (describing the difficulty in tracking individuals without                                 
            correct TIN’s in the IRS computer system).                                                 
                  Enforcing the SSN requirement also supports the Government’s                         
            compelling interest in implementing the Federal tax system in a                            
            uniform, mandatory way.  See Hernandez v. Commissioner, 490 U.S.                           
            680 (1989); United States v. Lee, 455 U.S. 252 (1982); Adams v.                            
            Commissioner, supra.  This interest extends both to the                                    
            imposition of taxes and to the administration of the tax system.                           
            See Steckler v. United States, 81 AFTR 2d 98-1049, at 98-1052,                             
            98-1 USTC par. 50,219, at 83,408 (E.D. La. 1998) (requirement                              

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