- 7 - TRHCA’s enactment date, December 20, 2006, and limited the application of TRHCA section 408 to those taxpayers whose liability arose or remained unpaid on or after that date. We perceive this to be a rational basis for the line drawn by Congress, and we reject petitioner’s argument to the contrary. Petitioner has also failed to demonstrate that TRHCA section 408 violates her right to due process. Petitioner appears to argue that TRHCA section 408 offends due process because it was not made retroactive to a date that would have enabled her to have her day in court with respect to the fully paid 1995-98 liabilities. Petitioner, however, has provided no support for her argument. Moreover, a taxpayer who pays a tax in full and complies with other jurisdictional prerequisites can pursue a refund action in a U.S. District Court or in the U.S. Court of Federal Claims. See sec. 7422(a). If petitioner believed that she should not have been liable for the taxes for 1995-98 that were reported and fully paid, she could have filed a refund claim and related litigation. It does not follow from the fact that petitioner is foreclosed from litigating in this Court because of a rational decision on Congress’s part to establish an effective date for TRHCA section 408 that petitioner’s constitutional right to due process has been violated. We reject petitioner’s due process argument as meritless.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: March 27, 2008