- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011