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therein a claim of defamation or any other nonphysical, personal
tort. See id.
We do not understand petitioner to be arguing, and in any
event we do not believe, that the injuries alleged in the lawsuit
by the plaintiffs of lost profits, loss of business, diminution
of sales, additional business expenses, a reduction in the value
of the plaintiffs' business, lost plants, and a diminution of the
value of the plaintiffs' nursery as a result of contamination of
the soil are personal injuries. We do not understand petitioner
to be claiming, and in any event we do not believe, that the
cause of the injuries that the plaintiffs alleged in the lawsuit,
i.e., negligent manufacture and sale of a defective product,
necessarily results in a personal injury within the meaning of
section 104(a)(2). Although the damage to the orchid plants of
the plaintiffs that they alleged in the complaint in the lawsuit
no doubt injured their business and, consequentially, their
business reputation, nowhere in the complaint in the lawsuit or
in the documents relating to the settlement of that lawsuit that
are before us is there any claim of personal injuries, as that
term is used in section 104(a)(2). See id. at 313.
On the record before us, we find that the plaintiffs' claims
for loss of business reputation and loss of reputation as orchid
growers are not on account of personal injuries within the
meaning of section 104(a)(2). See id. at 314. On that record,
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