Frank E. & Mildred E. Rickel v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that \it is judicially well-established that the meaning of `personal injuries' in this context encompasses both nonphysical as well as physical injuries\
• noting that “it is judicially well-established that the meaning of ‘personal injuries’ in this context encompasses both nonphysical as well as physical injuries”
• determining that the “Commissioner’s position could be deemed as reasonably supported in the case law” and holding on a particular issue that the Commissioner’s position was “substantially justified”
• rejecting a taxpayer's claim for costs award where \Commissioner's position could be deemed as reasonably supported in the case law\
• damages for economic harm flowing from a tortious injury as equally excludable as damages for physical harm
• “[A]ny accession to wealth is presumed to be gross income, unless the taxpayer can demonstrate that the accession fits into one of the specific exclusions created by other sections of the IRC.”

Source: CourtListener parenthetical corpus (CC0).