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because there is no evidence that United intended to compensate
petitioners for personal injuries or sickness.
E. Petitioners’ Injuries
Petitioners testified that they suffered sleep loss, damaged
credit, and anxiety from United’s failure to pay their insurance
claims. However, this does not establish that United intended to
pay damages on account of petitioners’ personal injuries or
sickness.
Petitioners contend that Hudson’s loss of credit is a
personal injury for purposes of section 104(a)(2) similar to the
injury to the taxpayer’s business reputation in Threlkeld v.
Commissioner, 87 T.C. 1294 (1986), affd. 848 F.2d 81 (6th Cir.
1988). We disagree. Regardless of the treatment of injury to
business reputation by courts in other cases, there is no
evidence that Hudson made that a part of his claim against United
or that United intended any part of the settlement to compensate
him for damages to his business reputation.
F. Conclusion
We conclude that the United payments to petitioners in 1994
were not on account of personal injuries or sickness. Thus,
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