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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
IRS.
On the record before us, we hold that for the taxable year
6(...continued)
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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