(DOWNLOAD) "Kovacs v. Commissioner of Internal Revenue" by Sixth Circuit U.S. Court of Appeals ~ Book PDF Kindle ePub Free
eBook details
- Title: Kovacs v. Commissioner of Internal Revenue
- Author : Sixth Circuit U.S. Court of Appeals
- Release Date : January 09, 1994
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 59 KB
Description
Per Curiam. In this appeal from the United States Tax Court, we are asked to decide whether interest paid on an award of damages for wrongful death is excludable as income under section 104(a)(2) of the Internal Revenue Code. That provision of the tax code excludes from gross income ""the amount of any damages received (whether by suit or agreement and whether as lump sums or as periodic payments) on account of personal injuries or sickness. . . ."" 26 U.S.C. § 104(a)(2) (emphasis added). ""Interest,"" on the other hand, is included in gross income under section 61(a)(4) of the Code. 26 U.S.C. § 61(a)(4). The Tax Court upheld the Commissioner's determination that the amounts in dispute here were subject to taxation as gross income to the petitioners. We agree and affirm.