Amanda Reynolds (Reynolds v. United States Internal Revenue Serv., Slip copy, 2025 WL 3514102 (E.D.N.Y. Dec. 8, 2025) is seeking a novel argument for domestic companion animals to be recognized under the Internal Revenue Code for tax purposes. Reynolds alleges constitutional violations from the IRS in excluding companion animals from qualifying as “dependents” for tax purposes, asserting claims under the Equal Protection and Due Process clauses.
Proceeding as pro se on behalf of herself, Finnegan (her dog) and other dog owner tax payers who are seeking tax relief, whether companion animals, and whether companion animals should be recognized as “dependents” under the Internal Revenue Code. (Id. at ¶¶ 1-5.)
Reynolds asserts two claims; (i) violations of the Fourteenth Amendment’s Equal Protection Clause and (ii) Substantive Due Process under the Takings Clause of the Fifth Amendment. (Id. at 5-6.) Specifically, Reynolds alleges that taxpayers who contribute financially to the maintenance of their dogs “meet or exceed the definitional criteria of ‘support’ under 26 U.S.C. § 152,” but are denied the ability to claim their animal’s status as a dependent “despite their dogs’ functional integration into the household.” (Id. at ¶ 2.)
Reynolds is seeking a) declare that dogs may qualify as non-human dependents under an amended reading of 26 U.S.C. Section 152; b) enjoin the IRS from categorically excluding dogs from dependent status without individualized consideration of functional dependency; and c) order the IRS to develop regulatory criteria for recognizing qualifying domestic companion animals as tax-relevant dependents.
This is an interesting idea. Let me know your thoughts and if you support.
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