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individual is the identifying number of the individual, except as
otherwise specified under the applicable regulations.
The regulations provide that an individual who is not
eligible to obtain a Social Security number and who is required
to furnish a taxpayer identifying number must apply for an ITIN.
Sec. 301.6109-1(d)(3)(ii), Proced. & Admin. Regs. An IRS ITIN is
a taxpayer identifying number issued to an alien individual by
the Internal Revenue Service, upon application, for use in
conjunction with requirements imposed by the Internal Revenue
Code. Sec. 301.6109-1(d)(3)(i), Proced. & Admin. Regs. An IRS
ITIN is not a Social Security number or an account number for use
in employment for wages. Id.
The regulations also provide that an individual who is duly
assigned a Social Security number or who is entitled to a Social
Security number will not be issued an IRS ITIN. Sec. 301.6109-
1(d)(4), Proced. & Admin. Regs.
In sum, an individual required to furnish a taxpayer
identification number must use the individual’s SSN unless the
individual is not eligible to obtain an SSN, in which case the
3(...continued)
may be entitled, and (2) a unique numerical identifier for the
individual for use by a variety of governmental and private
entities. See Miller v. Commissioner, 114 T.C. 511, 513-514
(2000).
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Last modified: May 25, 2011