The Receipt of Cash for Losses of Personal Rights
The D.C. Circuit’s first decision in Marrita Murphy v. IRS, concluding that a recovery for emotional distress was not taxable, received wide criticism. This viewpoint demonstrates that, contrary to conventional wisdom, the IRS before Murphy had a well-developed view that the receipt of cash for loss of a personal right was not a taxable event, regardless of whether any basis recovery or statutory exclusion was involved.
Marrita Murphy v. IRS, 46 F.3d 79 (D.C. Cir.), Compensation - Loss of Personal Rights, Taxable Income, Taxation, Accession to Wealth, IRC 14(a)(2)
Place of Original Publication
16 Tax Notes 103 (2010)
Jensen, Erik M., "The Receipt of Cash for Losses of Personal Rights" (2010). Faculty Publications. 698.