- 10 - 336 (1989), petitioner’s problem is that any rational basis-- whether articulated by Congress or hypothesized by a court--will suffice.8 One obvious rational basis for new section 6404(e)’s effective date is simple administrative convenience. In enacting new section 6404(e), Congress needed to define the situations that would and would not be subject to its provisions. Taking into account that income taxes are levied on an annual basis, it was rational for Congress to restrict the amendment’s application by tax year, limited to liabilities for tax years beginning after the date of enactment and so giving the IRS some time to adjust its own administrative routine at a lower cost to the Government. Considerations of administrative convenience have long been recognized as a valid reason for legislative line drawing. See N.Y. Rapid Transit, 303 U.S. at 580-581; Carmichael v. S. Coal & Coke Co., 301 U.S. 495, 511 (1937). We need not, indeed we must not, engage in judicial second-guessing of such a legislative decision: “The fact that another reasonable classification or 8 Courts have traditionally granted even greater deference to distinctions drawn by tax laws than they have to distinctions drawn by laws in other “rational basis” areas. See, e.g., Kelso, “Equal Protection After the Rational Basis Era: Is it Time to Reassess the Current Standards of Review?”, 4 U. Pa. J. Const. L. 225, 230-231 (2002) (recognizing that there exists a “second- order” rational review more stringent than the one applied in Allegheny Pittsburgh Coal).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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