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" ... Congress, the Court said, obviously did not intend this result when TRA 1986 was enacted — that is, to allow transactions that were purely tax motivated. It acted promptly in 1987 to correct the mistake, resulting in a modest retractive period of just over one year. Carlton’s reliance on the original statute to the estate’s detriment and his lack of notice of the change does not render the amendment unconstitutional. ... "