Dawson Craig Lane - Page 15

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          IRS individual taxpayer identification number is generally                  
          identified in the records and database of the IRS as a number               
          belonging to a nonresident alien individual.7  Sec. 301.6109-               
          1(g)(1)(iii), Proced. & Admin. Regs.  During the year at issue,             
          each of petitioner’s sons was a citizen and resident of the                 
          United States.                                                              
               We hold that, in order for petitioner to be entitled for the           
          taxable year 2001 to a personal exemption under section 151, see            
          sec. 151(a), (c), (e), and a child tax credit under section 24,             
          see sec. 24(a), (c), (e), for each of his sons, each of those               
          sons must have, and petitioner must provide to the IRS, a Social            
          Security number.  On the instant record, we find that neither of            
          petitioner’s sons has a Social Security number and that peti-               
          tioner failed to provide such a number for each such son to the             
               On the record before us, we hold that for the taxable year             

               thereunder. * * *                                                      
          Sec. 301.6109-3(a)(1), Proced. & Admin. Regs.                               
               The record does not establish that petitioner’s sons have              
          ever been placed for adoption.                                              
               7In the event that the IRS were to determine at the time an            
          individual applies for an IRS individual taxpayer identification            
          number, or thereafter, that such individual is not a nonresident            
          alien individual, the IRS may require such individual to apply              
          for a Social Security number.  Sec. 301.6109-1(g)(1)(iii),                  
          Proced. & Admin. Regs.                                                      

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Last modified: May 25, 2011