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on the origin and character of the claims adjudicated, and not
upon the validity of those claims. See Bent v. Commissioner,
87 T.C. 236 (1986), affd. 835 F.2d 67 (3d Cir. 1987); Glynn v.
Commissioner, 76 T.C. 116, 119 (1981), affd. without published
opinion 676 F.2d 682 (1st Cir. 1982); Seay v. Commissioner, 58
T.C. 32, 37 (1972). In this case, most of the amounts
petitioners received was for tortious interference with Mr.
Anderson’s business relationships and only a nominal amount was
received for slander. Both of Mr. Anderson’s claims of action
existed under Georgia law.
In Georgia, tortious interference with business
relationships requires the plaintiff to show that the
defendant: (1) Acted improperly and without privilege, (2)
acted purposely and with malice with intent to injure, (3)
induced a third party or parties not to enter into or continue
a business relationship with the plaintiff, and (4) caused the
plaintiff financial injury. See Renden, Inc. v. Liberty Real
Estate, Ltd., 444 S.E.2d 814 (Ga. Ct. App. 1994).
Respondent determined that the damages received by Mr.
Anderson for interference with his business relationships were
awarded on account of economic injuries, rather than personal
injuries. Supporting respondent’s determination, under Georgia
law a person’s business is property in the pursuit of which he
is entitled to protection. See NAACP v. Overstreet, 142 S.E.2d
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