Tonia V. Cates - Page 8




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          as early as 1994.  It is, therefore, highly unlikely that                   
          Rockford could have intended to compensate petitioner for her               
          hypertension because those symptoms appeared before petitioner              
          suffered any alleged racial discrimination at work.                         
               We hold that the $35,000 award for “emotional injuries” is             
          not excludable from gross income under section 104(a)(2).                   
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                             Decision will be entered                 
                                        for respondent.                               































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