Add to ORKGThis Note compares recent circuit cases reaching different opinions on whether punitive damages received on account of personal injuries are taxable under Internal Revenue Code section 104(a)(2). These differing opinions result in disparate taxation of federal taxpayers that violates the rule of uniformity in Article I, section 8, clause 1 of the United States Constitution. To provide a remedy, this Note proposes a rule to encourage the uniform application of federal income tax statutes
This paper will examine the history of damage award taxation beginning with the earliest income tax ...
Since 1919, statutory tax law has excluded from gross income compensatory damages received on accoun...
The United States Court of Appeals for the Third Circuit has held that in personal injury actions tr...
This Note compares recent circuit cases reaching different opinions on whether punitive damages rece...
The Internal Revenue Service and the courts have wavered on whether punitive damages are taxable und...
Section 104(a)(2) of the Internal Revenue Code excludes from gross income "the amount of any damages...
In Roemer v. Commissioner, the Ninth Circuit turned to California law to locate the meaning of pers...
Since the adoption in 1919 of the Revenue Act of 1918, damages received on account of personal injur...
For all practical purposes, the Constitution prescribes only one limit on the federal government\u27...
This article examines Section 104(a)(2) of the Internal Revenue Code and the litigation that has cen...
The Internal Revenue Code enacted in 1954 has continued the 1939 Code provision of law that damages ...
The Internal Revenue Code (Code) sweeps into gross income all income from whatever source derived, ...
The author explains that in recent court opinions and commentaries concerning whether punitive damag...
settled the ambiguous issue of when damages are excludible from gross income by amending section 104...
The income tax status of damage awards in personal injury actions assumes greater importance as liti...
This paper will examine the history of damage award taxation beginning with the earliest income tax ...
Since 1919, statutory tax law has excluded from gross income compensatory damages received on accoun...
The United States Court of Appeals for the Third Circuit has held that in personal injury actions tr...
This Note compares recent circuit cases reaching different opinions on whether punitive damages rece...
The Internal Revenue Service and the courts have wavered on whether punitive damages are taxable und...
Section 104(a)(2) of the Internal Revenue Code excludes from gross income "the amount of any damages...
In Roemer v. Commissioner, the Ninth Circuit turned to California law to locate the meaning of pers...
Since the adoption in 1919 of the Revenue Act of 1918, damages received on account of personal injur...
For all practical purposes, the Constitution prescribes only one limit on the federal government\u27...
This article examines Section 104(a)(2) of the Internal Revenue Code and the litigation that has cen...
The Internal Revenue Code enacted in 1954 has continued the 1939 Code provision of law that damages ...
The Internal Revenue Code (Code) sweeps into gross income all income from whatever source derived, ...
The author explains that in recent court opinions and commentaries concerning whether punitive damag...
settled the ambiguous issue of when damages are excludible from gross income by amending section 104...
The income tax status of damage awards in personal injury actions assumes greater importance as liti...
This paper will examine the history of damage award taxation beginning with the earliest income tax ...
Since 1919, statutory tax law has excluded from gross income compensatory damages received on accoun...
The United States Court of Appeals for the Third Circuit has held that in personal injury actions tr...