Paul S. Lindsey, Jr. and Kristen L. Lindsey - Page 8

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          that “emotional distress shall not be treated as a physical                 
          injury or physical sickness.”  Only reimbursements for actual               
          medical care for such injuries are now excludable.  The                     
          legislative history of this amendment clarifies that “the term              
          emotional distress includes symptoms (e.g., insomnia, headaches,            
          stomach disorders) which may result from such emotional                     
          distress.”  H. Conf. Rept. 104-737, at 301 n.56 (1996), 1996-3              
          C.B. 741, 1041 n.56.  Section 1605(d) of the SBJPA, 110 Stat.               
          1839, provides that (with an inapplicable exception) “the                   
          amendments made by this section shall apply to amounts received             
          after the date of the enactment of this Act, in taxable years               
          ending after such date.”  The SBJPA was enacted on August 20,               
          1996.  Id. at 1755.                                                         
               Petitioners contend that the “clear language” of section               
          1605(d) of the SBJPA dictates that the SBJPA amendments to                  
          section 104(a)(2) are not effective until 1997 because 1997 is              
          “the tax year ending after the effective date of the enactment of           
          the SBJPA”.  Petitioners argue that, if Congress had intended for           
          the amendments to become effective in the middle of a year, then            
          it could have unambiguously stated so.  Petitioners misinterpret            
          this statutory language.                                                    
               Petitioners’ 1996 taxable year ended December 31, 1996,                
          which is after the date of the enactment of the SBJPA.                      
          Petitioner received the settlement proceeds on December 17, 1996,           





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