- 15 - 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, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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