LOURIE, Circuit Judge.
Elizabeth A. Reese appeals from a decision of the United States Court of Federal Claims denying her motion for summary judgment and granting the United States' cross-motion for summary judgment. Reese v. United States, 28 Fed.Cl. 702 (1993). Because punitive damages received in settlement of civil litigation are not excludable from a taxpayer's "gross income" subject to federal income tax under section 104(a)(2) of the Internal Revenue...
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