- 13 - sioner, 116 T.C. 60, 62 (2001). Respondent summarily disallowed the dependency exemptions claimed for petitioner’s two sons in Form 1040A for 2001. That was because (1) section 151(e) provides that no dependency exemption is allowable “with respect to any individual unless the TIN of such individual is included on the return claiming the exemption”, and (2) Form 1040A for 2001 that petitioner filed stated “NONE” after the name of each of petitioner’s sons in the space provided in that form for “Dependent’s social security number”. Respondent assessed the tax for petitioner’s taxable year 2001 resulting from (1) respondent’s disallowance of the personal exemptions claimed in Form 1040A for 2001 for peti- tioner’s sons and (2) respondent’s allowance of a $600 rate reduction credit. Respondent’s assessment of that tax was proper under section 6213(b)(1) and (g)(2)(H).5 That is because such assessment arose out of a “mathematical or clerical error”. See sec. 6213(b)(1), (g)(2)(H). The definition of the term “mathematical or clerical error” includes “an omission of a correct TIN required under * * * section 151 (relating to allowance of deductions for personal exemptions)”. Sec. 6213(g)(2)(H). The term “TIN” means “the identifying number assigned to a person under section 6109." 5Respondent’s summary determination that petitioner is liable for 2001 for the addition to tax under sec. 6651(a)(2) also was proper. See secs. 6665, 6213(b).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011