legislation effectively validating a Treasury Department revenue rule that courts previously had found to expand impermissibly the definition of “wages” subject to FICA taxation beyond the scope of the statute. Id. at 21. After looking to the period of retroactivity (four years), the reliance interests of the parties, and whether the parties’ rights had vested, the court concluded that Congress had acted constitutionally with a curative intent to ratify the invalidated Treasury Department revenue rule, despite the longer than normal period of retroactivity. Id. at 25-27. GPX relies upon different tax cases, such as United States v. Carlton, which upheld retrospective tax legislation based on “only a modest period of retroactivity.” 512 U.S. 26, 32, 114 S.Ct. 2018, 129 L.Ed.2d 22 (1994) (<HOLDING>). Finding that the government has wide latitude
recognizing exception holding that the act is retroactive holding that the act is not retroactive recognizing that congress almost without exception enacts revenue statutes with retroactive effective dates holding retroactive application