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weaknesses. But the fact that another way may seem preferable to
petitioner does not mean that the manner chosen is without a
rational basis.3 Section 152(e) withstands petitioner’s
constitutional challenge.
Decision will be entered
for respondent.
3 At best petitioner’s argument is somewhat convoluted.
If there were an odd number of children involved, petitioner
acknowledges that equal apportionment of the sec. 151 dependency
exemption deduction would not be possible. Presumably, even
petitioner realizes that the answer could not be derived from
King Solomon’s wisdom.
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Last modified: May 25, 2011