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parameter. As Judge Garth observed in Estate of Kunkel v. United
States, 689 F.2d 408, 416 (3d Cir. 1982):
It is not for the courts to conduct a more exacting
inquiry into the "true" purpose of the statute, or to
ask whether some alternative means would have been more
closely tailored to achievement of the end sought.
In sum, to the extent there is a distinction between
employees and self-employed individuals in the application of the
AMT, it is a permissible byproduct of Congress's pursuit of a
legitimate governmental end. Whether another approach could have
been taken is beyond our limited scope of judicial review of the
determinations made by the legislative branch.
Based on the foregoing,
Decision will be entered
for respondent.
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