ALARCON, Circuit Judge:
Paul F. Roemer Jr. (Roemer) and Marcia E. Roemer appeal a decision of the United States Tax Court upholding a determination of deficiencies for their 1975 taxable year. Marcia E. Roemer is a party solely because she signed a joint income tax return with her spouse.
We must decide whether the defamation of an individual constitutes a personal injury for purposes of I.R.C. § 104(a)(2) (personal injury damages excludable from gross...
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