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simplifying administration, and in increased
effectiveness * * *
It is the Treasury Department’s judgment, based
upon close observation and study of the practical
workings of the withholding feature of the income-tax
law as well as of the general requirements of
administration, that information at the source is a
foundation upon which the administrative structure must
be built if the income-tax law is to be rendered most
effective and if due regard is to be paid to economy
and simplicity of administration and to the imposition
of no greater burden and expense upon taxpayers than is
necessary for effective administration. [S. Rept. 103,
65th Cong., 1st Sess. (1917), 1939-1 C.B. (Part 2) 56,
67-68.]
We find petitioner’s argument to be without merit. There is
no provision in the Internal Revenue Code which relieves a
taxpayer from liability for the income tax on gambling winnings
if the winnings are not reported by the payer. Thus, petitioner
essentially is arguing that he has not been afforded equal
protection because those taxpayers whose winnings were not
reported on informational returns have an easier time evading the
Federal tax laws. The statutory requirements for informational
returns classifies individuals according to the amount of
gambling winnings they pay to others. These classification
requirements are rationally related to the legitimate
governmental interest of balancing the need for reporting
requirements to ensure compliance with the tax laws and the need
to avoid imposing excessive burdens on covered individuals.
Requiring a casino to report every dollar won from every slot
machine would undoubtedly be such a burden.
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