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WOLFSON v. C. I. R.

Nos. 80-1043, 80-1044.

651 F.2d 1228 (1981)

William Q. WOLFSON and Elizabeth Wolfson, Petitioners-Appellants, Cross Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, Cross-Appellant.

United States Court of Appeals, Sixth Circuit.

June 24, 1981.

Attorney(s) appearing for the Case

Alan Adelson, Southfield, Mich., for petitioners-appellants, cross-appellees.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Daniel F. Ross, George L. Hastings, Jr., Tax Division, U. S. Dept. of Justice, N. Jerold Cohen, Chief Counsel, I. R. S., Washington, D. C., for respondent-appellee, cross-appellant.

Before JONES, Circuit Judge, CECIL, Senior Circuit Judge, and BERTELSMAN, District Judge.

ORDER

William Q. Wolfson appeals from the Tax Court's determination that the payment he received in settlement of his state court action against Wayne State University is includable in gross income because it was intended to compensate him for lost earnings, and was not a nontaxable form of compensation for personal injury to his personal reputation. Wolfson also contests the Tax Court's determination that funds he received while working as a medical resident were...

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