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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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