BIRCH, Circuit Judge:
In this tax appeal, we review whether punitive damages are taxable income, whether fees paid to attorneys based on a post-judgment, pre-appeal fee agreement must be included in gross income, and whether the position of the Internal Revenue Service ("IRS") in this litigation was substantially justified. The district court found that punitive damages were taxable income, that the portion of post-judgment interest paid to the taxpayer's attorneys...
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