Supreme Court of the United States
United States v. Carlton
June 13, 1994512 U.S. 26
Summary
The Court held that applying a 1987 amendment to the estate-tax ESOP deduction retroactively to transactions completed in 1986 did not violate the Due Process Clause. The amendment was rationally related to legitimate legislative purposes because it corrected an unexpectedly broad deduction, prevented a substantial and unanticipated revenue loss, and applied only after a modest period of retroactivity. The taxpayer's reliance on the original statute and lack of notice did not alone establish a constitutional violation.