HENRY, Circuit Judge.
Taxpayer Ila Gail appeals the district court's summary judgment order characterizing the proceeds of a judgment in a fraud and conversion action as income. We have jurisdiction pursuant to 28 U.S.C. § 1291. For the reasons set forth below, we reverse in part and remand to the district court.
BACKGROUND
Mrs. Gail is an elderly woman who owned an undivided one-half interest in ninety-six acres of real property in Trumball...
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