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have not applied for Social Security numbers on behalf of any of
their children, nor has any of their children received a Social
Security number.
In August 1997, petitioners timely filed an income tax
return, Form 1040, for 1996. On their return, petitioners
claimed deductions for dependency exemptions for their four
children. Under the column for “Dependent’s social security
number”, petitioners wrote “none” opposite each of the four
children’s names.
No taxpayer, other than petitioners, claimed deductions for
dependency exemptions for any of petitioners’ children for 1996.
In February 2000, respondent issued a notice of deficiency
to petitioners determining a deficiency in their income tax for
1996. The notice includes the following explanation for
respondent’s action:
We are unable to allow the exemptions claimed for your
three daughters and son for 1996. In order to claim an
exemption for each of them, you must provide us with
their social security numbers. If the children are
unable to secure social security numbers and you wish
to claim an exemption for them, then you must secure an
individual taxpayer identification number.
Respondent concedes that for 1996, petitioners are entitled
to deductions for dependency exemptions for their children but
for petitioners’ failure to include their children’s Social
Security numbers on petitioners’ return.
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Last modified: May 25, 2011