You represent City A, Ohio. City A levies a city income tax on residents of City A at the rate of 2%. Under City A's income tax code, City A residents are taxed at the rate of 2% on all of their income wherever earned (i.e., whether earned in City A or outside of City A). Nonresidents that work in City A are taxed on 2% of their income that is earned within City A. Under City A's income tax code, residents that earn income outside of City A are permitted an income tax credit for income taxes paid to another city up to 1% of the Taxpayer's income (i.e., up to 50% of the income taxes owed to City A). City's A income tax is levied and administered by City A, such tax is collected by City A, and the tax revenues from such tax are used to benefit City A.

A resident of City A, Ohio ("Mr. Taxpayer") has notified that the Tax Commissioner that he believes that the City's taxing statute is unconstitutional because it does not permit a full credit for income taxes paid to other cities (i.e., up to the 2% tax rate). Mr. Taxpayer works in City B, Ohio and is subject to city income tax imposed on nonresidents in City B, Ohio at a rate of 2%. Thus, Mr. Taxpayer pays a city income tax in City B, Ohio at a 2% rate and city income tax in City A, Ohio at a rate of 1% (for a total tax rate of 3%). Mr. Taxpayer believes that he should receive a full credit in City A (up to the 2% rate) for income taxes paid to other cities (rather than only up to 1%).

City A, Ohio has asked you whether its tax code is unconstitutional under the U.S. Constitution (ignore any State constitutional arguments) because City's A code does not offer a full income tax credit for residents that pay income taxes to other cities. Provide your response. If the answer is not clear, be sure to address both sides of the argument.