Dawson Craig Lane - Page 16

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          2001 petitioner is not entitled to a personal exemption or a                
          child tax credit for either of his two sons.  We further hold               
          that petitioner’s refusal, apparently on moral or religious                 
          grounds, to obtain from the Social Security Administration and to           
          provide to the IRS a Social Security number for each of his sons            
          does not excuse him from the requirements of sections 151(e) and            
          24(e) for the taxable year 2001.  See Miller v. Commissioner, 114           
          T.C. 511 (2000).                                                            
               Based upon our examination of the entire record before us,             
          we find that respondent may proceed with the collection action as           
          determined in the notice of determination with respect to peti-             
          tioner’s unpaid liability for 2001.                                         
               We turn now to respondent’s motion for a penalty under                 
          section 6673 (respondent’s motion).  Section 6673(a)(1) autho-              
          rizes the Court to require a taxpayer to pay the United States a            
          penalty in an amount not to exceed $25,000 whenever it appears to           
          the Court, inter alia, that a proceeding before it was instituted           
          or maintained primarily for delay, sec. 6673(a)(1)(A), or that              
          the taxpayer’s position in such proceeding is frivolous or                  
          groundless, sec. 6673(a)(1)(B).                                             
               Although we shall not impose a penalty under section                   
          6673(a)(1) on petitioner in the instant case, we caution him that           
          he may be subject to such a penalty if in the future he insti-              
          tutes or maintains a proceeding in this Court primarily for delay           

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