Paul S. Leblanc - Page 5




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          See Regan v. Taxation With Representation, 461 U.S. 540, 547                
          (1983).  We apply a higher standard of review only if it is found           
          that the statute (1) impermissibly interferes with the exercise             
          of a fundamental right, such as freedom of speech, or (2) employs           
          a suspect classification, such as race.  See, e.g., id.; Harris             
          v. McRae, 448 U.S. 297, 322 (1980).  Neither of these exceptions            
          applies in this case.  Under the rational basis standard, a                 
          challenged classification is valid if rationally related to a               
          legitimate governmental interest.  See City of Cleburne v.                  
          Cleburne Living Ctr., Inc., 473 U.S. 432, 440 (1985); City of New           
          Orleans v. Dukes, 427 U.S. 297, 303 (1976).  Legislatures have              
          especially broad latitude in creating classification and                    
          distinctions in tax statutes.  See Regan v. Taxation With                   
          Representation, supra at 547.                                               
               The informational return which petitioner’s wife received in           
          this case was required by section 6041 and the accompanying                 
          regulations.  As a general rule, a person engaged in a trade or             
          business who makes a payment to an individual in excess of $600             
          must provide an informational return to the Secretary of the                
          Treasury (or his delegate) and to the individual.  See sec.                 
          6041(a), (d).  A person engaged in a trade or business who pays             
          winnings to an individual of $1,200 or more from a bingo game or            
          slot machine play, or of $1,500 or more from a keno game, must              
          provide such an informational return.  See sec. 7.6041-1(a),                






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