This article covers recent significant developments affecting taxation of individuals, including legislative changes, cases, regulations, and other IRS guidance. The items are arranged in Code section order. The Treasury Inspector General for Tax Administration (TIGTA) semi-annual report to Congress for the period October 2008-March 2009 includes a recommendation that legislation is needed to clarify whether refundable tax credits, such as the additional child tax credit, may be paid to filers without valid Social Security numbers. Currently, an individual taxpayer identification number (ITIN) is available to any resident or nonresident alien who is unable to obtain an SSN but has a tax return filing requirement. Each year the IRS approves billions of dollars in tax credits claimed by G?? filers without adequate verification of eligibility. In tax year 2007, for example, more than 1.2 million (66%) ITIN filers received additional child tax credits of $1.8 billion. The TIGTA report says payment of federal funds to ITIN filers is inconsistent with federal law and policy