John W. and Faythe A. Miller - Page 11




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            under section 3401(a)(1) that taxpayer’s SSN be disclosed when                             
            redeeming Treasury bonds was the least restrictive means of                                
            meeting the Government’s compelling interests “in collecting                               
            taxes fairly, in administering its tax system properly, and in                             
            making sure all citizens participate in that system on equal                               
            terms”).                                                                                   
                  Petitioners argue that enforcing the SSN requirement against                         
            them is not the least restrictive means of achieving these                                 
            government interests because the IRS waives the SSN requirement                            
            for taxpayers who qualify for exemption from Social Security                               
            taxes under section 1402(g).  This practice was acknowledged in                            
            the legislative history accompanying the enactment of the TIN                              
            requirement of former section 6109(e),6 in the Tax Reform Act of                           
            1986, Pub. L. 99-514 100 Stat 2085:                                                        
                  The conferees note that certain taxpayers, because of their                          
                  religious beliefs, are exempted from Social Security self-                           
                  employment taxes (section 1402(g)).  The conferees intend                            
                  that these taxpayers and their dependents who currently                              
                  acquire their TIN’s from the IRS continue to be permitted to                         







                  6Former sec. 6109(e) required a taxpayer who claimed the                             
            deduction for the dependency exemption under sec. 151(c) to                                
            provide the dependent's TIN.  Sec. 151(e) requires the same                                
            information as did former sec. 6109(e) but changes the                                     
            enforcement mechanism for the TIN requirement from an information                          
            reporting penalty to a disallowance of the deduction.                                      





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