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816 (Ga. 1965). Tortious interference with business relations
involves interference with the plaintiff’s current and future
property rights derived from current or potential customers.
See id. at 823; see also Renden, Inc. v. Liberty Real Estate,
Ltd., supra at 817. Petitioners have not shown that the
damages received were for personal injury under Georgia law.
Damages received in a tort action may be excluded from income
only when received on account of personal injury; therefore,
petitioners’ damages received for tortious interference with
business relationships must be included in income. Even if the
holding in NAACP v. Overstreet, supra, was not intended to
limit tortious interference with business relationships to a
property tort, petitioners have still failed to prove that they
received damages on account of personal injury. Accordingly,
we sustain respondent’s determination on this issue.
Petitioners argue that the personal injury to Mr.
Anderson’s business reputation constituted the requisite
“improper means” element of the tortious interference claim.
Georgia courts have held that in order to satisfy all the
elements in a claim for tortious interference with business
relationships, there must be a finding that the defendant used
improper means. See Contractors’ Bldg. Supply, Inc. v.
Gwinnett, 403 S.E.2d 844 (Ga. Ct. App. 1991). “Improper means”
may be shown in several ways including: Fraud,
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