§1615

claiming the exemptions. Although respondent's counsel accurately recited the current rule of law provided in section 151(e), such rule was not effective during the taxable years in issue. Small Business Job Protection Act of 1996, Pub. L. 104-188, sec. 1615(d), 110 Stat. 1755, 1853. Accordingly, we hold that petitioner is entitled to dependency exemption deductions for his two sons for 1992, 1993, 1994. The fourth issue for decision is whether petitioner is liable for the section 6651(a)(1) ad

A correct Social Security number was never provided.8 Section 151(c) allows a taxpayer to deduct an annual exemption amount for each dependent, as defined in section 152.

le 142(a). The parties have stipulated that petitioners’ children are U.S. citizens, and petitioners do not contend that their children are 3 Sec. 151(e), which was added to the Code by the Small Business Job Protection Act of 1996, Pub. L. 104-188, sec. 1615(a)(1), 110 Stat. 1853, generally applies to returns due on or after Sept. 19, 1996. - 5 - ineligible for SSN’s. Thus, under section 151(e) and the applicable regulations, petitioners cannot properly claim dependency exemption deductions for