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  5. 843 F.Supp. 1119 (1994)
 

ESTATE OF WESSON v. U.S.

Civ. A. No. 1:93-CV-62RR.

843 F.Supp. 1119 (1994)

ESTATE OF Ray L. WESSON, Deceased, E. Hall, Administrator, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, S.D. Mississippi, S.D.

February 8, 1994.

Attorney(s) appearing for the Case

Clyde H. Gunn, Biloxi, MS, Frank J. Hammond, III, Jackson, MS, for plaintiff.

William D. Holmes, Atty., Tax Div., U.S. Dept. of Justice, Washington, DC, for defendant.

MEMORANDUM ORDER

DAN M. RUSSELL, Jr., District Judge.

This matter is before the Court on Plaintiffs Motion for Summary Judgment and Defendant's Cross-Motion for Summary Judgment. The sole issue presented for resolution is whether punitive damages received in a bad-faith action should be excludable from taxable gross income under 26 U.S.C. secs. 61 & 104(a)(2).

Background

The relevant facts are undisputed. In 1982, beneficiaries of a...

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