Court of Appeals for the Third Circuit October 1, 2001, 00-1802 (Charles Francisco Cecilia Francisco v. United States)

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United States · · · 01-10-2001

OPINION OF THE COURT

AMBRO, Circuit Judge.

This tax case presents two questions. First, are “delay damages,” received by the plaintiff in a personal injury tort action pursuant to Pennsylvania Rule of Civil Procedure 238, exempt from federal income taxation as damages “received on

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account of’ a personal injury? 26 U.S.C. § 104(a)(2).

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