- 6 - 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 usePage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: March 27, 2008