Reasonable classification principle: differential deadline for charitable trust tax recognition cannot lack rational basis or equality protection. A departmental circular extended a filing deadline for tax recognition to mitigate hardship but excluded newly formed charitable trusts without offering ... Summary
Reasonable classification principle: differential deadline for charitable trust tax recognition cannot lack rational basis or equality protection.
A departmental circular extended a filing deadline for tax recognition to mitigate hardship but excluded newly formed charitable trusts without offering reasons; the exclusion lacked an intelligible differentia and rational nexus to the circular's object, making the differential treatment arbitrary and ultra vires the constitutional guarantee of equality, requiring the excluded applications to be treated as within time and decided on merits.
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TaxTMI 
TaxTMI 
