- 15 - 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.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