Labels:book | reckoner | sky OCR: 1986 Regulation in this case would violate the Due Process Clause. This Court's precedents establish the doubtful of the Govemment's construction First retroactive tax statute judged undei the following standard: [The court] must consider the nature of the tax and the cirrumstances iT which laid before can said that tetroactive application harsh oppressive to transgress the constihutional limitation One the relevant circumstances whether without notice statute gives diffe rent and more oppressiye legal effect conduct undertaken before enactment the statute United States Hemme, 476 U.S. 558, 568 69 (1986) (quoting We{ch Henry 305 U.S 134. 147 (1938)); see aiso Untermver 276 U.S 445 (holding original 1924 gift tax unconstitutional). Retroactive application tax statute accorded particular scr ...
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