- 4 - Petitioners have raised a variety of arguments that the payments by the insurance companies do not constitute gross income. They contend that the factual situation here is analogous to the situation where an insured automobile is damaged in an accident. The insurance company insuring the vehicle pays the body shop for the cost of the repairs, and, in such a situation, the payments do not constitute gross income to the vehicle owner. Moreover, petitioners argue, the payments at issue were not unemployment benefits, and, additionally, since the insurance payments approximately equaled the interest due on the credit card liabilities and portions of the insurance premiums, petitioners realized no economic benefits from the insurance payments because the debts on each credit card remained unpaid, and for which they remained liable. Finally, petitioners argue that they were not the beneficiaries on the insurance contracts, and the banks were the beneficiaries. Because petitioners were not beneficiaries under the terms of the insurance contracts, petitioners contend the amounts paid by the insurance companies were not a benefit to them. Section 61 provides that gross income includes "all income from whatever source derived," unless otherwise provided. The Supreme Court has consistently given this definition of gross income a liberal construction "in recognition of the intention of Congress to tax all gains except those specifically exempted."Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011