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exemption disputes, and clarify which of two divorced parents
would receive the dependency exemption. Knight v. Commissioner,
T.C. Memo. 1992-710, affd. 29 F.3d 632 (9th Cir. 1994); H. Rept.
98-432 (Part 2), supra at 1498. Because section 152(e) eases the
administrative burden of the IRS and thereby advances enforcement
of the statute in a rational way, it furthers a legitimate
congressional purpose. Knight v. Commissioner, supra.
Therefore, section 152(e) does not violate the Due Process Clause
of the Fifth Amendment to the Constitution of the United States.
Id. Accordingly, we hold that petitioner is not eligible for a
dependency exemption or a child tax credit for the taxable year
2003.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: November 10, 2007