- 14 - statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification.” FCC v. Beach Communications, Inc., 508 U.S. 307, 313 (1993). One reasonably conceivable explanation for the classification embodied in the net worth limitation is that Congress believed taxpayers with net worths exceeding the limitation were less vulnerable to unjustified interest charges because such taxpayers were better able to make an advance payment of tax or to post a cash bond, thereby limiting the accrual of interest during a dispute with the Commissioner. Cf. Rev. Proc. 84-58, 1984-2 C.B. 501 (establishing procedures for making an advance payment or posting a cash bond). We believe a rational basis exists for the net worth limitations of section 6404(i); consequently, the provision does not violate the Equal Protection Clause. Because petitioner’s net worth, determined as required by section 7430(c)(4)(D)(i)(I), does not meet the requirements of section 7430(c)(4)(A)(ii), this Court does not have jurisdiction.6 6 In light of this conclusion, we find it unnecessary to address respondent’s alternative argument that, even if petitioner’s net worth is to be determined as of the date of filing the petition, such net worth must include all assets in the estate, including assets already distributed. See Estate ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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