What Is the Moritz v. Commissioner of Internal Revenue Case?

A tax disagreement involving a single man and his elderly mother became a foundational moment in legal history. The case centered on Charles E. Moritz, who was denied a tax deduction for his mother’s care expenses based solely on his gender and marital status. This dispute, originating from a specific provision in the U.S. tax code, escalated into a challenge against gender-based discrimination, questioning the stereotypes embedded within federal law. The case of Moritz v. Commissioner of Internal Revenue demonstrated how a personal financial issue could challenge the constitutionality of a federal law.

The Caregiver Deduction Dispute

Charles E. Moritz, a single man who had never married, was the primary caregiver for his 89-year-old invalid mother, who lived with him. His work required him to travel, making it necessary to hire outside help for his mother’s care. For the 1968 tax year, Moritz claimed a deduction for the $600 he paid to a caregiver.

The basis for the conflict was Section 214 of the Internal Revenue Code. This provision allowed a deduction for caregiving expenses for a child or disabled dependent but explicitly limited it by gender and marital status. The deduction was available to women, widowers, divorced men, and husbands with incapacitated wives. Because Moritz had never been married, he was ineligible under the text of the law.

The Internal Revenue Service (IRS) disallowed the deduction, reasoning that Moritz did not meet the statutory requirements. Moritz challenged this decision in the U.S. Tax Court, which upheld the IRS’s position in 1970. This ruling created the legal grounds for an appeal.

The Constitutional Argument

The case then shifted from a tax matter to a constitutional challenge, guided by a legal team that included law professor Ruth Bader Ginsburg and her husband, Martin D. Ginsburg, working with the American Civil Liberties Union (ACLU). They saw an opportunity to use the case to establish a precedent against gender discrimination.

The core of their legal strategy was that Section 214 violated the Equal Protection Clause of the Fourteenth Amendment to the U.S. Constitution. The argument was that the law created a distinction based solely on sex without a rational basis. The legal team contended that the statute was built on discriminatory stereotypes about the roles of men and women, specifically the assumption that caregiving was exclusively women’s work.

The choice of a male plaintiff was strategic. By representing a man who was being discriminated against by the law, the ACLU aimed to demonstrate that gender-based classifications harmed everyone, not just women. This approach was designed to persuade an all-male panel of judges that the principle of equal protection should apply to any law that draws arbitrary lines based on sex.

The Tenth Circuit’s Decision

The United States Court of Appeals for the Tenth Circuit reversed the Tax Court’s decision, ruling in favor of Charles Moritz in 1972. The court’s judgment was a rejection of the gender-based classification in the Internal Revenue Code. The decision focused on whether the law’s distinction between men and women served a legitimate legislative purpose.

The court analyzed the government’s justifications for the law and found them wanting. It concluded that denying the deduction to a man who had never been married, while granting it to others, was not related to any valid objective. The judges stated that the classification based on sex was “an invidious discrimination and invalid under due process principles,” viewing the distinction as arbitrary and unfair.

In its ruling, the Tenth Circuit determined that the differential treatment of Moritz constituted a violation of the Equal Protection Clause. The court reasoned that if Congress intended to provide tax relief for those with caregiving burdens, it could not do so through discrimination based solely on sex. By finding the provision invalid, the court extended the benefit of the deduction to the taxpayer, setting a legal precedent that would influence future challenges to laws that discriminated on the basis of gender.