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FABRY v. C.I.R.

No. 99-12407.

223 F.3d 1261 (2000)

Carl J. FABRY, Patricia P. Fabry, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eleventh Circuit.

August 21, 2000.

Attorney(s) appearing for the Case

Brian J. Moran, Moran & Shams, P.A., John Michael Brennan, Gray, Harris & Robinson, P.A., Orlando, FL, for Petitioners.

Kenneth W. Rosenberg, Kennth L. Greene, Dept. of Justice, Appellate Tax Div., Washington, DC, for Respondent.

Before DUBINA, BLACK and HILL, Circuit Judges.

HILL, Circuit Judge:

This tax case presents a single issue: are damages to business reputation received in the amount of $500,000 by taxpayers in 19921 in settlement of their tort action for strict liability and negligence against the manufacturer of an allegedly defective product properly excludable from gross income under Internal Revenue Code (IRC) § 104(a)(2) as "damages received ... on account of personal injuries"? Under a ...

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