Cite as: 512 U. S. 26 (1994)
Opinion of the Court
the deduction to those who made purely tax-motivated stock transfers was not unreasonable. Moreover, the amendment's retroactive application is rationally related to its legitimate purpose, since Congress acted promptly in proposing the amendment within a few months of § 2057's original enactment and established a modest retroactivity period that extended only slightly longer than one year. The Court of Appeals' exclusive focus on the taxpayer's notice and reliance held § 2057 to an unduly strict standard. Pp. 30-35.
972 F. 2d 1051, reversed.
Blackmun, J., delivered the opinion of the Court, in which Rehnquist, C. J., and Stevens, Kennedy, Souter, and Ginsburg, JJ., joined. O'Connor, J., filed an opinion concurring in the judgment, post, p. 35. Scalia, J., filed an opinion concurring in the judgment, in which Thomas, J., joined, post, p. 39.
Kent L. Jones argued the cause for the United States. With him on the brief were Solicitor General Days, Acting Assistant Attorney General Paup, Deputy Solicitor General Wallace, Gilbert S. Rothenberg, and Teresa E. McLaughlin.
Russell G. Allen argued the cause and filed a brief for respondent. With him on the brief was Phillip R. Kaplan.*
Justice Blackmun delivered the opinion of the Court.
In 1987, Congress amended a provision of the federal estate tax statute by limiting the availability of a recently added deduction for the proceeds of sales of stock to employee stock-ownership plans (ESOP's). Congress provided that the amendment would apply retroactively, as if incorporated in the original deduction provision, which had been adopted in October 1986. The question presented by this case is whether the retroactive application of the amendment violates the Due Process Clause of the Fifth Amendment.
*Briefs of amici curiae urging affirmance were filed for the Washington Legal Foundation et al. by Joseph E. Schmitz, Charles A. Shanor, Daniel J. Popeo, and Paul D. Kamenar; and for Anthony C. Morici, Jr., Executor and Trustee of the estate of McNamee, by Charles C. Marson.
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