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violate * * * Equal Protection * * * merely because the classifi-
cations made by its laws are imperfect.” Dandridge v. Williams,
397 U.S. 471, 485 (1970).
The question is simply whether the classification is
rationally related to a legitimate legislative goal. Granting
relief to bona fide real estate professionals reflects such a
goal; appropriately, Congress considered factors which tend to
show active involvement in that industry, such as being an
owner–employee of a real estate business.
In light of Congress’ broad latitude as to classifications
in tax statutes, we conclude that section 469(c)(7)(D)(ii) is
constitutionally valid, as it rationally serves a legitimate
public purpose. To reflect concessions and our conclusion
herein,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011