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gross income. See Hardin v. Commissioner, T.C. Memo. 1997-202;
Raney v. Commissioner, T.C. Memo. 1997-200; Clark v.
Commissioner, T.C. Memo. 1997-156; Berst v. Commissioner, T.C.
Memo. 1997-137; Martinez v. Commissioner, T.C. Memo. 1997-126;
Fredrickson v. Commissioner, T.C. Memo. 1997-125. We hold
similarly today. Petitioner has presented no new arguments which
would change our view on the instant issue, and we continue to
adhere to our view as espoused in those Memorandum Opinions for
the reasons stated therein.
Petitioner's primary argument is that she received her
proceeds under a cause of action arising from the Civil Rights
Act of 1991 (the CRA of 1991), Pub. L. 102-166, sec. 102, 105
Stat. 1071, 1072-1073, and that the CRA of 1991 provides tort
type damages that compensate for personal injury. Petitioner
argues that the CRA of 1991 governs her case because Judge Lynch
signed State Farm's offer to the class after the CRA of 1991 was
signed into law. We considered petitioner's primary argument in
Clark v. Commissioner, supra, and we rejected it there. We do
likewise today.
We hold for respondent. In so doing, we have considered all
arguments made by petitioner for a contrary holding, and, to the
extent not discussed above, find them to be irrelevant or without
merit. To reflect concessions by respondent,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011