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exemptions. See Miller v. Commissioner, supra; Kocher v.
Commissioner, supra; Davis v. Commissioner, supra. The SSN
serves as a mechanism in determining whether an SSN has been
claimed on another return for the year and serves as verification
of the existence of a claimed dependent. See Miller v.
Commissioner, supra at 516-517. Petitioners’ attempt at limiting
the applicability of section 151(e) is, therefore, without merit.
In view of the foregoing, we hold that section 151(e) is not
unconstitutional as alleged by petitioners. We hold further that
by virtue of that section, petitioners’ failure to provide Social
Security numbers for their children on their income tax return
precludes the allowance of deductions for dependency exemptions
for their children. See Miller v. Commissioner, supra; Kocher v.
Commissioner, supra; Davis v. Commissioner, supra;.
We have considered all of the other arguments made by
petitioners, and, to the extent that we have not specifically
addressed them, we find them to be without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011