Ross Gable Cansino and Mary Ann Cansino - Page 10




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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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