Mapes v. United States
United States Court of Claims
576 F.2d 896 (1978)
- Written by Whitney Punzone, JD
Facts
Prior to marriage, Paul Mapes and Jane Bryson (collectively, the couple) (plaintiffs) entered into an oral prenuptial agreement regarding their income. After marriage, in 1976, the couple sought a refund of $1,220.10 for additional taxes paid to the Internal Revenue Service (IRS) (defendant) as a result of being married. Based on Internal Revenue Code (IRC) § 1, the couple’s tax liability for 1976 was $8,532.10. If unmarried, their combined liability would have been $7,312. The couple argued that IRC § 1 (the so-called marriage penalty) was unconstitutional because it (1) burdened the fundamental right to marry, (2) had a discriminatory impact on women by treating wives as secondary earners and husbands as primary, and (3) was invalid under a 1931 Supreme Court decision in which the Court invalidated a Wisconsin law that taxed spouses’ combined income without providing an alternative. The couple also sought to distinguish a recent decision in which a federal district court had rejected similar constitutional arguments against the marriage penalty because that case did not involve a prenuptial agreement. The IRS argued that it was impossible to have a marriage-neutral tax system. The parties cross-moved for summary judgment.
Rule of Law
Issue
Holding and Reasoning (Nichols, J.)
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