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Income Tax Keyed to Bankman
Murphy v. United States
Citation:
493 F.3d 170 (D.C. Cir. 2007), cert. denied, 553 U.S. 1004 (2008)Facts
In 1994, Petitioner filed a complaint with the Department of Labor against her former employer, the New York Air National Guard, claiming that it had violated several whistle-blower statutes against her. The Department of Labor found in her favor and an Administrative Law Judge determined Petitioner was entitled to compensatory damages totaling $70,000. In 2000, Petitioner included the $70,000 as income and paid $20,655 in taxes on the award. Petitioner subsequently filed an amended return claiming the $70,000 was excludable under § 104(a)(2) and requested a refund of the $20,655 she had paid. Her request was denied on the grounds that her compensatory damages were not due to personal injury or sickness as required by the statute. Petitioner then sued the United States for a refund in the United States District Court.
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