Miller v. Commissioner
United States Tax Court
Ps claimed dependency exemptions on their 1996 joint Federal income tax return without furnishing SSN's for their children, as required under sec. 151(e), I.R.C. Ps seek relief from the SSN requirement because of their religious beliefs in opposition to using SSN's.
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Ps claimed dependency exemptions on their 1996 joint Federal income tax return without furnishing SSN's for their children, as required under sec. 151(e), I.R.C. Ps seek relief from the SSN requirement because of their religious beliefs in opposition to using SSN's. HELD: the SSN requirement is the least restrictive means of achieving the Government's compelling interests in implementing the Federal tax system in a uniform, mandatory way and in detecting fraud in regard to dependency exemptions. Accordingly, neither the Free Exercise Clause of the First Amendment to the Constitution nor the…
1Opinion of the Court
OPINION
Laro, Judge:
This case is before the Court fully stipulated. See Rule 122. Petitioners petitioned the Court to redetermine respondent’s determination of a $1,391 deficiency in Federal income tax for 1996.
The issue in this case is whether requiring petitioners to provide Social Security numbers (ssn’s) for their dependent children as a condition to allowing their dependency deductions violates petitioners’ right to free exercise of religion. We hold that it does not.
Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue. Rule…
2Cases cited9 opinions
- Sherbert v. VernerSupreme Court of the United States · 1963
- Employment Div., Dept. of Human Resources of Ore. v. SmithSupreme Court of the United States · 1990
- City of Boerne v. FloresSupreme Court of the United States · 1997
- Thomas v. Review Board of the Indiana Employment Security DivisionSupreme Court of the United States · 1981
- Hernandez v. CommissionerSupreme Court of the United States · 1989
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