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The issue for decision is whether, by virtue of section
151(e),1 petitioners’ failure to provide Social Security numbers
for their children on their income tax return precludes the
allowance of deductions for dependency exemptions for the
children. We hold that petitioners’ failure precludes the
allowance of the deductions.
Background
This case was submitted fully stipulated under Rule 122, and
the facts stipulated are so found. Petitioners resided in George
West, Texas, at the time that their petition was filed with the
Court.
Petitioners are U.S. citizens who are husband and wife.
They were married in San Antonio, Texas, in October 1989, and
remained married throughout 1996, the taxable year in issue.
Petitioners are the parents of four children: Katheryn A.
Cansino, born in October 1990; Elizabeth M. Cansino, born in
April 1993; Jesse R. Cansino, born in July 1994; and Mary V.
Cansino, born in August 1995. All four children were born in
Houston, Texas, and are citizens of the United States.
Petitioner Ross Gable Cansino and petitioner Mary Ann
Cansino each have Social Security numbers. However, petitioners
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1996, the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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