- 7 - See Miller v. Commissioner, 114 T.C. 511 (2000); see also Kocher v. Commissioner, T.C. Memo. 2000-238; Davis v. Commissioner, T.C. Memo. 2000-210 (involving both RFRA and the Privacy Act of 1974, 5 U.S.C. sec. 552a (1994)). Petitioners have given us no persuasive reason to revisit any of those cases. Accordingly, we hold that petitioners’ religious belief does not negate the requirement of section 151(e) that a taxpayer include on the taxpayer’s return the SSN of any child whom the taxpayer claims as a dependent. We turn now to petitioners’ contention that section 151(e) violates the Equal Protection and Due Process Clauses of the 14th Amendment to the Constitution, as well as the Due Process Clause of the 5th Amendment. Petitioners assert that the requirement to provide SSN’s for their children violates equal protection principles because it is over-inclusive. Petitioners argue that the SSN requirement “should have been tailored so as to apply only to those individual parents who are both likely to take the deductions for their children not to all parents.” Petitioners seek to have the SSN requirement imposed for a distinct class of individuals, namely: (1) Those involved in divorce proceedings; (2) paternity suits; or (3) other domestic relations proceedings. We disagree. Initially, we note that this Court has held that the 14th Amendment does not apply to Federal tax statutes. See Labay v.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011