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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
age:
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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