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Constitutional Limitations: Tan v. Del Rosario, Supra
Constitutional Limitations: 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.