and those that exist in organizational forms other than trusts are governed by § 1.511-2(a). Therefore, the Trust’s reliance upon the Treasury Regulations is misplaced. The Trust also invokes legislative history in support of its argument. Because the relevant Code provisions are unambiguous, however, there is no need to consult legislative history. See, e.g., Meyers v. Columbia/HCA Healthcare Corp., 341 F.3d 461, 472 (6th Cir.2003) (“Where the language of the statute is not ambiguous, it is unnecessary to resort to legislative history.”). Finally, the Trust raises a claim of disparate treatment. There is no dispute that, as a general matter, similarly situated taxpayers should not be treated differently. See Oshkosh Truck Corp. v. United States, 123 F.3d 1477, 1481 (Fed.Cir.1997) (<HOLDING>). The Trust asserts that it is the victim of
holding that a causal connection may be established indirectly with circumstantial evidence for example by showing that the protected activity was followed by discriminatory treatment or through evidence of disparate treatment of employees who engaged in similar conduct or directly through evidence of retaliatory animus holding that title vii claims of disparate treatment based on discriminatory overtime survive summary judgment holding that discrimination can be established through other evidence such as disparate treatment of fellow employees who engaged in similar conduct holding that absent a rational reason for disparate treatment similarlysituated taxpayers should be treated in a similar fashion recognizing that one way to prove pretext is by showing that similarlysituated employees were treated differently