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Income Tax Keyed to Bankman
Perez v. Commissioner
Citation:
144 T.C. 51 (2015)Facts
Petitioner contracted with an egg donation company called Donor Source International, LLC, which specializes in connecting egg donors with infertile women and couples. The contract Petitioner signed provided that she must participate in good faith to produce eggs and that she would be compensated for her time, effort, inconvenience, pain and suffering. Petitioner would still receive compensation even if at the end of the process she did not produce any viable eggs. Petitioner was able to produce eggs and repeated the process again, earning $20,000 in a year. Petitioner failed to report this compensation as income, claiming that it was excludable as damages for physical injury under § 104(a)(2) of the Internal Revenue Code.
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