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Petitioner has not argued, and she has failed to
demonstrate, that she is a member of any suspect classification
or that TRHCA section 408 interferes with a fundamental right.
Consequently, we must uphold TRHCA section 408 if it bears a
rational relationship to a legitimate governmental purpose. See
Regan v. Taxation With Representation, supra at 547. We have
held that it is especially difficult to demonstrate that no
rational basis exists for a classification in a revenue act for
which the presumption that an act of Congress is constitutional
is particularly strong. See Black v. Commissioner, 69 T.C. 505,
507-508 (1977); Cansino v. Commissioner, T.C. Memo. 2001-134.
Moreover, under the rational basis standard, a statute does not
violate the equal protection mandate “if any state of facts
rationally justifying * * * [the statute] is demonstrated to or
perceived by the courts.” United States v. Md. Savings-Share
Ins. Corp., 400 U.S. 4, 6 (1970).
One obvious rational basis for Congress’s choice of an
effective date is administrative convenience. Administrative
convenience has been recognized as a sufficient reason for
legislative line drawing. See, e.g., N.Y. Rapid Transit Corp. v.
City of New York, 303 U.S. 573, 580 (1938). In enacting TRHCA
section 408, Congress had to draw a line that would enable the
Internal Revenue Service and the courts to ascertain when TRHCA
section 408 would apply. Congress reasonably decided to use
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