- 6 - U.S. 540, 547 (1983). The rational basis standard dictates that a statutory provision does not violate equal protection “if any state of facts rationally justifying it is demonstrated to or perceived by the courts.” United States v. Md. Savings-Share Ins. Corp., 400 U.S. 4, 6 (1970). Moreover, a classification that has some reasonable basis does not violate the Constitution simply because it “is not made with mathematical nicety, or because in practice it results in some inequality.” Lindsley v. Natural Carbonic Gas Co., 220 U.S. 61, 78 (1911); Bryant v. Commissioner, 72 T.C. 757, 764 (1979). This case does not involve a fundamental right or suspect class. Prior to 1984, a noncustodial parent could claim a dependency exemption pursuant to section 152(e) if he or she provided $1,200 or more for the support of a child and the custodial parent could not clearly establish that he or she provided more support than the noncustodial parent. This provision required the IRS to wade into disputes between parents “who both [claimed] the dependency exemption based on providing support over the applicable thresholds.” H. Rept. 98-432 (Part 1), at 197 (1984). Thus, Congress added the written declaration requirement to section 152(e) to eliminate the role of the IRS as mediator between divorced or separated parents, provide more certainty to the “often subjective and * * * difficult problems of proof and substantiation” that accompanied dependencyPage: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007