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Protection Clause of the 14th Amendment. Johnson v. Robison, 415
U.S. 361, 364-365 n.4 (1974); Ward v. Commissioner, supra;
Stevenson v. Commissioner, T.C. Memo. 1981-127.
Under equal protection analysis, a classification in a Federal
statute is subject to strict scrutiny only if it interferes with
the exercise of a fundamental right or operates to the peculiar
disadvantage of a suspect class. Regan v. Taxation with
Representation, 461 U.S. 540, 547 (1983); Massachusetts Bd. of
Retirement v. Murgia, 427 U.S. 307, 312 (1976); San Antonio Indep.
Sch. Dist. v. Rodriguez, 411 U.S. 1, 16-17 (1973). Neither
circumstance is present here. Wealth discrimination alone is
insufficient to require strict scrutiny; such review of wealth
classifications has been applied only where the discrimination
affects an important individual interest. See, e.g., San Antonio
Indep. Sch. Dist. v. Rodriguez, supra at 24, 29; Harper v. Virginia
State Bd. of Elections, 383 U.S. 663 (1966).
Where a tax statute results in differing treatment of
different classes of persons, the statute generally is not in
violation of the Fifth Amendment because of the different treatment
if it has a rational basis. Regan v. Taxation with Representation,
supra; United States v. Maryland Savings-Share Ins. Corp., 400 U.S.
4 (1970). Furthermore, it is especially difficult to demonstrate
that no rational basis exists for a classification in a revenue
measure for which the presumption that an act of Congress is
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