Field v. Comr., T.C. Memo. 2013-111

(petitioner claimed I.R.C. Sec. 23(a) credit for qualified adoption expenses but petitioner did not file joint return with spouse for tax year in which credit claimed (as required by Sec. 23); IRS denied credit and petitioner claimed denial of credit violated petitioner's equal protection rights under Constitution; court disagreed with petitioner on basis that law clear and reasonable basis existed for requiring joint return to claim credit).