Clayton v. United States

Denise Clayton and Leann Harris appeal the district court’s order granting summary judgment in favor of the United States on them tax refund suit, 26 U.S.C. § 7422 (2000). At issue is whether the proceeds from the settlement of a suit involving an inter vivos trust are excludable as income received by inheritance, 26 U.S.C. § 102(a) (2000), or as damages received on account of personal physical injuries or physical sickness within the meaning of 26 U.S.C. § 104(a)(2) (2000). We have reviewed the record included on appeal as well as the parties’ briefs, and have found no reversible error. We…