Charles E. Moritz v. Commissioner of Internal Revenue
469 F.2d 466, 31 A.F.T.R.2d (RIA) 308, 1972 U.S. App. LEXIS 6610 (1972)
Sections
Rule of Law:
A federal tax statute that grants dependent care deductions to women, widowers, and divorcés but denies them to single men who have never married creates an invalid classification based on sex in violation of the Due Process Clause of the Fifth Amendment.
Facts:
- Charles E. Moritz was a single man who had never married and lived in Denver.
- He worked as an editor for a publishing firm, a position that required extensive travel throughout the western United States.
- His 89-year-old mother, who suffered from arthritis, memory loss, and other disabilities, lived with him and refused to enter a nursing home.
- To provide for her care and allow himself to continue working, Moritz hired a woman to provide general care for his mother at his home.
- In the tax year 1968, Moritz paid this caregiver $1,250 and furnished her meals.
- Section 214 of the Internal Revenue Code specifically allowed a tax deduction for such care expenses for women, widowers, divorcés, or husbands with incapacitated wives.
- The statute explicitly excluded single men who had never married from claiming this deduction.
Procedural Posture:
- The Commissioner of Internal Revenue denied Moritz's claimed deduction for dependent care expenses and assessed a tax deficiency.
- Moritz filed a petition challenging the deficiency in the United States Tax Court.
- The Tax Court sustained the Government's position and ruled that Moritz was not entitled to the deduction.
- Moritz appealed the Tax Court's decision to the United States Court of Appeals for the Tenth Circuit.
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Issue:
Does a federal tax statute that allows a deduction for dependent care expenses to women and formerly married men, but denies the same deduction to single men who have never married, constitute invidious discrimination in violation of the Fifth Amendment?
Opinions:
Majority - Judge Holloway
Yes, the denial of the deduction to single men who have never married is unconstitutional because the sex-based classification lacks a fair and substantial relation to the legislative objective. The court first established that the expenses were legitimately for the purpose of enabling Moritz to work. Moving to the constitutional question, the court rejected the government's argument that tax deductions are a privilege immune from scrutiny, stating that even legislative grace cannot be based on invidious discrimination. Applying the principles of Reed v. Reed, the court subjected the sex-based classification to heightened scrutiny. The court reasoned that there was no rational basis to grant relief to women and widowers while denying it to single men, as the burden of dependent care is not logically related to the taxpayer's sex or marital history. Finding the classification invalid under the Due Process Clause, the court determined the appropriate remedy was to extend the benefit to the excluded class rather than invalidate the entire statute.
Analysis:
This decision represents a pivotal moment in the application of equal protection principles to the Internal Revenue Code. It establishes that tax laws are not immune from constitutional scrutiny regarding sex discrimination. By applying the standard from Reed v. Reed, the court rejected the historical assumption that caregiving is the primary domain of women. The case is also legally significant for its remedial approach; rather than striking down the deduction entirely (which would harm all taxpayers), the court utilized the doctrine of extension to include the previously excluded class, illustrating a judicial preference for preserving legislative benefits while curing constitutional defects.
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