While millions of U.S. households (about 94 million families) own one or more pets, pets are not considered part of the family for tax purposes. A recently filed case in district court aims to change that. Amanda Reynolds, an attorney licensed in New York and Utah who focuses largely on civil litigation insurance defense, recently filed a complaint in the Eastern District of New York, together with Finnegan Mary Reynolds. The catch? Finnegan is Amanda’s dog.

Reynolds says that Finnegan, her eight-year-old golden retriever, is entirely dependent on her for food, shelter, medical care, training, transportation, and daily living. Finnegan has no independent income, resides exclusively with her, and has annual expenses exceeding $5,000. That means, Reynolds argues, that Finnegan satisfies every meaningful element of dependency recognized under section 152 of the Internal Revenue Code—except for being human. As a result, Reynolds has asked the court to determine whether pets can be recognized as non-human dependents under federal tax law.

This unequal treatment, she says, lacks a rational basis, especially considering the IRS’s own recognition that some animals—specifically, service dogs—may qualify for tax advantages. Reynolds argues that, from a financial standpoint, there is no real difference between service animals and companion animals.