Moritz v. Commissioner
United States Tax Court
Petitioner, an unmarried, past or present, male, deducted $ 600 for care of his invalid mother under sec. 214, I.R.C. 1954. He contends denial of the deduction to him is arbitrary, capricious, and unreasonable in that other single persons, widowers and single women, are entitled to it.
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Petitioner, an unmarried, past or present, male, deducted $ 600 for care of his invalid mother under sec. 214, I.R.C. 1954. He contends denial of the deduction to him is arbitrary, capricious, and unreasonable in that other single persons, widowers and single women, are entitled to it. Held, the legislative history of sec. 214 plainly discloses that petitioner is not within that class of persons covered by sec. 214. Held, further, there is no violation of due process since all members of the class of persons to which petitioner belongs are treated similarly.
1Opinion of the Court
OPINION
Tietjens, Judge:
The Commissioner determined a deficiency in petitioner’s Federal income tax for taxable year 1968 in the amount of $328.80. The issue before us is whether petitioner is entitled to a deduction under section 214 for expenses paid for the care of his mother.
All of the facts are stipulated and are so found.
Petitioner Charles E. Moritz, resided in Denver, Colo., at the time of the filing of the petition herein. He is single and has never been married. During 1968 petitioner served as editor for the western division of the publishing firm of Lea & Febiger. He maintained an…
2Cases cited3 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Dorothy Shinder v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
3Cited by36 opinions
- Charles E. Moritz v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1972
- O'Donnell v. CommissionerUnited States Tax Court · 1974
- Guest v. CommissionerUnited States Tax Court · 1979
- Cohen v. CommissionerUnited States Tax Court · 1974
- Estate of Klein v. CommissionerUnited States Tax Court · 1975
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