James C. Harris - Page 6




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          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 dependency                    







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