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answered:
It was fatigue, stress, headaches, the fact that I was going
around like a zombie, the fact that I had –- that I was
making bad decisions. There's –- that pretty much covers
everything, but it was such a tremendous amount of stress
that I was having a hard time dealing with life, and it was
manifesting itself.
Petitioner also contends that his physical and emotional injuries
were a contributing cause of his subsequent commission of a
felony for which he was sentenced to prison.
No action was ever instituted by petitioner against PayLess
for the above injuries petitioner described, nor do any of the
settlement documents between PayLess and its former employees
address any specific injury to any of the former employees who
instituted the action, including petitioner as a member of the
class.
Section 104(a)(2) provides that gross income does not
include "the amount of any damages received (whether by suit or
agreement* * *) on account of personal injuries or sickness".
Under section 1.104-1(c), Income Tax Regs., "damages" means a
recovery "based upon tort or tort type rights". See also
Commissioner v. Schleier, 515 U.S. 323 (1995). While personal
injuries, under section 104(a)(2), may generally include both
physical as well as nonphysical emotional injuries, such as "pain
and suffering, emotional distress, harm to reputation, or other
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