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LINDSEY v. C.I.R.

No. 04-2978.

422 F.3d 684 (2005)

Paul S. LINDSEY, Jr.; Kristen Lindsey, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eighth Circuit.

Filed: September 2, 2005.

Attorney(s) appearing for the Case

Dwight E. Cole, argued, St. Louis, Missouri (Jim J. Shoemake and Matthew S. McBride, on the brief), for petitioners.

John A. Nolet, argued, Washington, D.C. (Eileen J. O'Connor and Kenneth L. Greene, on the brief), for respondent.

Before WOLLMAN, HANSEN, and RILEY, Circuit Judges.

RILEY, Circuit Judge.

In December 1996, Paul S. Lindsey, Jr. (Lindsey), then controlling owner, chairman, and chief executive officer of Empire Gas Corporation (EGC), received $2 million as part of a final corporate settlement. Lindsey received the payment "in settlement of his claims for tortious interference with contracts, for personal injury including injury to Mr. Lindsey's personal and professional reputation and emotional distress, humiliation and embarrassment...

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