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legitimately impose “reasonable regulations that do not
significantly interfere with decisions to enter into the marital
relationship”); Califano v. Jobst, 434 U.S. 47, 58 (1977) (Social
Security classifications that had a tangential impact upon a
marital decision did not violate due process). As previously
discussed, section 2035(c) is rationally related to a legitimate
governmental purpose. The estate’s suggestion that the
Constitution requires married persons and single persons to be
taxed identically is refuted by a long line of cases. See, e.g.,
Ensminger v. Commissioner, 610 F.2d 189 (4th Cir. 1979), affg.
T.C. Memo. 1977-224; Mapes v. United States, 217 Ct. Cl. 115, 576
F.2d 896, 904 (1978) (“there cannot be a ‘marriage neutral’ tax
system”); DeMars v. Commissioner, 79 T.C. 247, 250-251 (1982)
(requiring married persons to combine their adjusted gross
incomes to determine eligibility for disability income exclusion
has a rational basis); Druker v. Commissioner, 77 T.C. 867, 872-
873 (1981) (“the differences in exposure to tax liability between
married and single persons do not rise to the level of an
impermissible interference with the enjoyment of the fundamental
right to marry or remain married”), affd. on this issue and revd.
in part 697 F.2d 46 (2d Cir. 1982); Kellems v. Commissioner, 58
T.C. 556 (1972) (finding that geographic equalization of
taxpayers in community and noncommunity property States, as well
as greater financial burdens of married persons, constitutes a
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