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U.S. 540, 547 (1983), which presumption has been described as
“particularly strong”, Nammack v. Commissioner, 56 T.C. 1379,
1385 (1971), affd. per curiam 459 F.2d 1045 (2nd Cir. 1972); see
Black v. Commissioner, 69 T.C. 505, 507-508 (1977). Generally,
statutory classifications are valid if they bear a rational
relation to a legitimate governmental purpose. See Regan v.
Taxation With Representation, supra. A higher level of scrutiny
is applied if a statute interferes with the exercise of a
fundamental right, such as freedom of speech, or employs a
suspect classification, such as race. See, e.g., id.; Harris v.
McRae, 448 U.S. 297, 322 (1980).
Congress's power to categorize and classify for tax purposes
is extremely broad. See Regan v. Taxation With Representation,
supra; Lehnhausen v. Lake Shore Auto Parts Co., 410 U.S. 356, 359
(1973); Charles C. Steward Mach. Co. v. Davis, 301 U.S. 548, 584
(1937); Brushaber v. Union Pac. R.R., 240 U.S. 1, 26 (1916);
Flint v. Stone Tracy Co., 220 U.S. 107, 158 (1911); see also
Barter v. United States, 550 F.2d 1239, 1240 (7th Cir. 1977) (per
curiam) (statutory difference in tax rates for married couples
and single individuals does not violate Due Process of law of the
Fifth Amendment; “perfect equality or absolute logical
consistency between persons subject to the Internal Revenue Code
* * * [is not] a constitutional sine qua non”). In Regan v.
Taxation With Representation, supra at 547-548, the Supreme Court
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