Section 13 Equal Protection

• Library: Tax Law 2009

Equal protection does not require identical treatment. It does not even require the absence of discrimination. It merely provides
thata classification must be the product of real differences, the difference must be related to the purpose for which the distinction is noted,and any difference in treatment cannot be simply a product
of whimsical or capricious choice. See generally Walters v. City of St. Louis, Mo., 347 U.S. 231 (1954). While an equal protection argument is often combined with or inseparable from a uniformity argument, the taxpayer’s concern may be more about discrimination in treatment within a classification than about a distinction among...