- 11 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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