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Co., 348 U.S. 426 (1955). Although section 61(a) is to be
broadly construed, statutory exclusions from income are narrowly
construed. Commissioner v. Schleier, supra at 327-328; Kovacs v.
Commissioner, 100 T.C. 124, 128 (1993), affd. without published
opinion 25 F.3d 1048 (6th Cir. 1994).
Under section 104(a)(2), gross income does not include "the
amount of any damages received (whether by suit or agreement and
whether as lump sums or as periodic payments) on account of
personal injuries or sickness". Section 1.104-1(c), Income Tax
Regs., provides in pertinent part:
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