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CONSTITUTIONAL LIMITATIONS

2. EQUAL PROTECTION OF THE LAWS

Tan v. Del Rosario, supra.

 The said law is not arbitrary; it is germane to the purpose of the law and; applies to all things
of equal conditions and of same class.

 It is neither violative of equal protection clause due to the existence of substantial difference
between one who practice his profession alone and one who is engaged to proprietorship.

 Further, the SC said that RA 7496 is just an amendatory provision of the code of taxpayers
where it classifies taxpayers in to four main groups: Individuals, Corporations, Estate under
Judicial Settlement and Irrevocable Trust. The court would have appreciated the contention
of the petitioner if RA 7496 was an independent law. But since it is attached to a law that has
already classified taxpayers, there is no violation of equal protection clause.

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