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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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Last modified: November 10, 2007