William Q. Wolfson and Elizabeth Wolfson, Cross v. Commissioner of Internal Revenue, Cross-Appellant

ORDER

William Q. Wolfson appeals from the Tax Court’s determination that the payment he received in settlement of his state court action against Wayne State University is includable in gross income because it was intended to compensate him for lost earnings, and was not a nontaxable form of compensation for personal injury to his personal reputation. Wolfson also contests the Tax Court’s determination that funds he received while working as a medical resident were gross income paid in return for services he rendered, instead of nontaxable fellowship grants.

In 1943, Wolfson received his medical…