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United States v. Md. Savings-Share Ins. Corp., 400 U.S. 4, 6
(1970). Moreover, “congressional judgments in the form of
‘irrebuttable presumptions’ in the economic area will be upheld
where there is a rational relationship between the criteria set
forth in the statutory mandate and a legitimate congressional
purpose.” Sakol v. Commissioner, 574 F.2d 694, 698 (2d Cir.
1978), affg. 67 T.C. 986 (1977). Generally, the alleviation of
“administrative burdens and practical problems of enforcement”
constitutes a legitimate congressional purpose. Bryant v.
Commissioner, 72 T.C. 757, 766 (1979).
By enacting the current version of section 152(e), Congress
sought to avoid the very type of factual debates that petitioner
advances regarding the expenses of supporting and raising
children, and to ease the administrative burden that was placed
on the IRS when it became involved in these types of disputes.
Knight v. Commissioner, T.C. Memo. 1992-710. Section 152(e)
gives the custodial parent the deduction and the ability to waive
it for the benefit of the noncustodial parent. Id. This eases
the administrative burden on the IRS and advances enforcement of
the statute in a rational way; therefore, section 152(e) does not
violate the Due Process Clause of the Fifth Amendment of the
Constitution of the United States. Id.
To be sure, there are other ways that Congress could have
resolved the problem, and each way would have strengths and
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