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Coke Co., 301 U.S. 495, 509-510 (1937); Cash v. Commissioner, 580
F.2d 152, 155 (5th Cir. 1978) (different tax rates for single and
married taxpayers are constitutional), affg. T.C. Memo. 1977-405;
Barter v. United States, 550 F.2d 1239, 1240 (7th Cir. 1977)
(same). By limiting the tax deduction at issue here to artists
with incomes under $16,000, Congress clearly intended to benefit
low-income performing artists. We believe there is a rational
basis for targeting the provision at issue here to performing
artists with adjusted gross incomes not in excess of $16,000
because they have a greater need for assistance than higher
income performing artists.
Petitioner points out that a statute, constitutionally valid
when enacted, may become invalid by a change in the conditions to
which it is applied, citing Baker v. Carr, 369 U.S. 186, 254, n.6
(1962), and contends that the $16,000 ceiling in section 62
violates due process because the statute contains no provision to
adjust for inflation. Petitioner cites no authority, and we know
of none, supporting his contention that Congress’s failure to
adjust for inflation the $16,000 ceiling in section 62(b)(1)
invalidates the statute.
Finally, petitioner contends that we must carefully consider
whether taxes imposed on performing artists, which petitioner
views as a “politically impotent class”, are discriminatory. See
United States v. Onslow County Bd. of Educ., 728 F.2d 628, 642
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