Ronald W. Ramey and Joni J. Ramey - Page 14




                                        -13-                                          
          sufficient to show petitioner’s personal injury or qualification            
          for exclusion.  Pipitone v. United States, 180 F.3d at 863-865,             
          (citing Kurowski v. Commissioner, 917 F.2d 1033, 1036 (7th Cir.             
          1990), affg. T.C. Memo. 1989-149).  We hold that the damages                
          received were on account of the FLSA for back wages, liquidated             
          damages, attorney’s fees and costs, and not for personal injury.            
               To the extent not herein discussed, we have considered all             
          other arguments made by the parties and conclude they are moot or           
          without merit.                                                              
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               



























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