New York attorney Amanda Reynolds is suing the IRS to classify her golden retriever, Finnegan, as a tax dependent. She argues that Finnegan relies entirely on her for food, shelter, veterinary care, training, and more, with annual costs over $5,000 and no independent income—meeting most criteria under Section 152 of the Internal Revenue Code except being human. The lawsuit seeks to allow pet owners access to tax benefits like the Child Tax Credit, Earned Income Tax Credit, Dependent Care Credit, and head-of-household status. Reynolds claims the current rules violate equal protection and amount to an uncompensated taking of property. The IRS has moved to dismiss the case, citing lack of standing and clear tax law limiting dependents to humans. A federal magistrate judge has called the claims meritless, stayed discovery, and noted that dogs cannot qualify as dependents under existing law. While unlikely to succeed, the case highlights the growing view of pets as family members and the financial burden of pet ownership.
Long Version
A Dog’s Day in Court: Attorney Sues IRS to Classify Pets as Dependents
In a bold and unconventional move that’s capturing the attention of pet owners and taxpayers alike, New York attorney Amanda Reynolds has filed a federal lawsuit against the Internal Revenue Service (IRS), demanding that her beloved golden retriever, Finnegan—formally known as Canine Finnegan or Finnegan Mary Reynolds—be recognized as a dependent under U.S. tax law. 0 This case, docketed as Amanda Reynolds v. United States, No. 2:25-cv-03447 in the Eastern District of New York, challenges longstanding interpretations of the Internal Revenue Code and highlights the evolving role of pets in modern families. 12
The Plaintiff and Her Furry Family Member
Amanda Reynolds, an attorney specializing in civil litigation and insurance defense, licensed in both New York and Utah, is no stranger to the courtroom. But this lawsuit is personal. Reynolds, who describes herself as a devoted “pup-mom,” has raised her eight-year-old golden retriever, Finnegan, as a central part of her life. She argues that Finnegan relies entirely on her for essentials like food, shelter, medical care, training, transportation, and overall daily living—mirroring the support provided to human dependents. 0 As a companion animal and emotional support provider, Finnegan has become one of Reynolds’ furry family members, attending daycare while she works and accompanying her through life’s ups and downs.
Reynolds emphasizes the financial burden of pet ownership. Annual expenses for Finnegan exceed $5,000, covering veterinary care, veterinary bills, food, shelter, and other necessities. Despite this, current tax law treats these as personal expenses, offering no tax relief or tax advantages comparable to those for human dependents. 0 Reynolds contends that Finnegan has no independent income, resides exclusively with her, and incurs costs that rival or exceed those for children, making a compelling case for dependency status.
The Core of the Lawsuit: Challenging Section 152 of the Internal Revenue Code
At the heart of the complaint is Section 152 of the Internal Revenue Code, which defines dependents for tax purposes. 0 This section outlines criteria for qualifying children and qualifying relatives, focusing on factors like relationship, residency, support, and income thresholds. Reynolds asserts that Finnegan satisfies every meaningful element of dependency except for being human. She argues that the tax code’s exclusion of non-human dependents is arbitrary and unfair, especially given the similar responsibilities pet owners shoulder.
The lawsuit seeks a declaratory judgment from the court, asking it to determine whether pets can qualify as non-human dependents under federal tax law. 1 If successful, this could unlock tax benefits such as the Child Tax Credit, Additional Child Tax Credit, Credit for Other Dependents, Earned Income Tax Credit, Dependent Care Credit, and even Head-of-Household Filing Status for eligible taxpayers. 0 These tax-favored credits and deductions provide significant tax relief, including a higher standard deduction and potentially lower tax rates, reducing the overall tax bill and easing the taxpayer’s burden.
Reynolds also highlights disparities in tax treatment. For instance, service animals qualify for medical deductions, allowing owners to deduct costs related to their care as medical expenses on Form 1040. 0 Business-related animals, like guard dogs, may yield tax deductions as well. Even charitable deductions are available for fostering animals through qualified organizations. Yet, for everyday companion animals like Finnegan, no such provisions exist, despite the emotional support and financial burden they impose.
Constitutional Arguments: Equal Protection and Takings Clause
Beyond the tax code, Reynolds invokes constitutional principles. She claims the IRS’s policy violates the Equal Protection Clause under the 14th Amendment by discriminating against pet owners without a rational basis, treating human and non-human dependents differently despite comparable support needs. 0 Additionally, she argues it infringes on the Takings Clause of the 5th Amendment, as denying tax breaks for pet care effectively increases tax assessments and collections, amounting to an uncompensated taking of property.
Reynolds positions dogs as “quasi-citizens” deserving limited civil recognition, including dependency status for tax purposes. 0 She rejects the traditional classification of dogs as mere property, advocating for a modern view that acknowledges their role in providing companionship and support, much like family members.
The IRS’s Response and Court Proceedings
The IRS has responded assertively, signaling an intent to file a motion to dismiss. 0 In a pre-motion conference letter, the agency outlined several defects: lack of standing due to no alleged actual injury (Reynolds hasn’t claimed Finnegan on a tax return), improper service, and failure to state a viable claim. The Anti-Injunction Act and Declaratory Judgment Act further bar suits challenging tax collections or seeking declaratory relief on federal taxes.
Magistrate Judge James M. Wicks, assigned to handle pretrial matters, has already granted the IRS’s motion to stay the discovery process pending the anticipated motion to dismiss. 0 This stay avoids unnecessary burden and prejudice while threshold issues are resolved. Reynolds did not oppose the stay, anticipating a largely paper-based litigation. Legal experts view the case as potentially frivolous or meritless, with little chance of surviving dismissal, as tax law explicitly interprets “individuals” in Section 152 as humans only. 10
Key hurdles include standing requirements: plaintiffs must show actual injury, causation, and redressability. 0 Without attempting to claim Finnegan as a dependent and facing denial, Reynolds’ claims may lack the concrete harm needed for federal court jurisdiction.
Broader Implications for Pet Owners and Tax Law
This lawsuit resonates with millions of pet owners who view their animals as integral family members, facing substantial annual expenses without corresponding tax deductions or benefits. 3 If the court rules in Reynolds’ favor—though unlikely—it could revolutionize tax advantages for companion animals, extending beyond dogs to other pets and potentially alleviating the financial burden of veterinary care, food, shelter, and more.
However, precedent suggests otherwise. Tax law prioritizes human dependents, and attempts to expand definitions have historically failed. Still, the case sparks important discussions about evolving societal norms, where pets provide emotional support and companionship akin to children. For now, pet owners must rely on limited options like medical deductions for service animals or exploring charitable contributions for animal-related expenses.
As the motion to dismiss looms, this case serves as a fascinating intersection of tax law, animal rights, and family dynamics. Whether it advances to full litigation or ends swiftly, it underscores the passion of taxpayers like Reynolds, who see their dogs not just as pets, but as dependents deserving of recognition under the tax code. Stay tuned for developments in this unique legal battle.
