John W. and Faythe A. Miller - Page 13

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                  We also reject petitioners’ suggestion that respondent could                         
            accommodate petitioners’ religious beliefs by issuing ITIN’s to                            
            petitioners’ children.  We find that issuing ITIN’s would be a                             
            less effective means of detecting fraud than requiring SSN’s.                              
            For one, issuing an ITIN to an individual who is otherwise                                 
            eligible to receive an SSN creates the risk that the individual                            
            will thereafter obtain an SSN.  The individual will then have two                          
            TIN’s, each intended by the system to be a unique identifier.  In                          
            such case, cross-matching of the individual’s TIN’s would not                              
            reveal the existence of a duplicate claim.                                                 
                  We have considered all of the other arguments made by                                
            petitioners and, to the extent we have not addressed them, find                            
            them to be without merit.                                                                  
                  In accordance with these findings, we hold that petitioners                          
            are not exempt from furnishing SSN’s for their children in                                 
            claiming them as dependents.                                                               
                                                        Decision will be entered for                   

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