ROEMER v. C.I.R.

No. 82-7695.

716 F.2d 693 (1983)

Paul F. ROEMER, Jr. and Marcia E. Roemer, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 22, 1983.


Attorney(s) appearing for the Case

John Gigounas, San Francisco, Cal., for petitioners-appellants.

Jay W. Miller, Washington, D.C., for respondent-appellee.

Before ALARCON, CANBY, and REINHARDT, Circuit Judges.


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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