Richard D. Anderson and Mary L. Anderson - Page 15




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          tortious interference with business relationships were received             
          on account of personal injuries within the meaning of section               
          104(a)(2).  Although the facts reflect that the defendants’                 
          conduct may have damaged Mr. Anderson’s business reputation,                
          the vast majority of the recovery was for property damages                  
          caused by interference with Mr. Anderson’s business                         
          relationships.  In Commissioner v. Schleier, 515 U.S. 323                   
          (1995), the Supreme Court cautioned that there must be a direct             
          link between the cause of harm and its effect for the section               
          104(a)(2) exclusion to apply.  Petitioners have failed to show              
          such a link between an injury to Mr. Anderson’s business                    
          reputation caused by the defendants’ actions and the economic               
          loss for which Mr. Anderson recovered.  Therefore, petitioners              
          have failed the second prong of the Schleier test with regard               
          to the damages received under Mr. Anderson’s claim for tortious             
          interference with business relationships.  Accordingly we                   
          sustain respondent’s determination on this issue.                           
               We must now examine the second claim for which petitioners             
          received damages.  In Mr. Anderson’s second claim, he alleged               
          that the defendants “intentionally, willfully, and maliciously”             
          acted to cause injury to petitioner’s ”peace, happiness, and                











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