Moritz v. Commissioner
1972 American sex discrimination case
Charles E. Moritz v. Commissioner of Internal Revenue, 469 F.2d 466 (1972), was a case before the United States Court of Appeals for the Tenth Circuit in which the Court held that discrimination on the basis of sex constitutes a violation of the Equal Protection Clause of the United States Constitution. Charles Moritz had claimed a tax deduction for the cost of a caregiver for his invalid mother and the Internal Revenue Service had denied the deduction. The law specifically allowed such a deduction, but only for women and formerly married men, which Moritz was not.
The United States Tax Court agreed with the IRS's decision to deny the deduction, but on appeal the Tenth Circuit Court of Appeals overturned that decision, holding that the tax code conflicted with the Equal Protection Clause of the U.S. Constitution and extending the caregiver deduction to never-married men.
Background
Section 214
During the 1968 tax year, Section 214 of the Internal Revenue Code provided that certain taxpayers could claim a tax deduction for expenses relating to the care of the taxpayer's dependent:
Sec. 214. Expenses for care of certain dependents
(a) General rule.-There shall be allowed as a deduction expenses paid during the taxable year by a taxpayer who is a woman or widower, or is a husband whose wife is incapacitated or is institutionalized, for the care of one or more dependents (as defined in subsection (d) (1)), but only if such care is for the purpose of enabling the taxpayer to be gainfully employed. ...
(d) Definitions.-For purposes of this section- ...
Begin with the source’s own compact description: “Moritz v. Commissioner” is 1972 American sex discrimination case. The dossier treats that line as a proposition to test through Moritz, Commissioner and American, not as a finished interpretation.
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