United States Sixth Circuit

Plaintiff's qui tam relator's award is not excludable from gross income where the underlying cause of action is based upon contract fraud inflicted upon the government, not a tort inflicted upon the relator, and that the award was not on account of personal injuries inflicted upon himself.

Appellate Information

• Argued 08/05/2004
• Decided 09/10/2004
• Published 09/10/2004

Judges

• Before: KENNEDY, SUTTON, and COOK, Circuit Judges.

Court

• United States Sixth Circuit

Counsel

• For Appellees:
  
• Philip E. Wilson (argued and briefed), Wilson Law Office, Lexington, KY, for Plaintiff-Appellant.David E. Middleton, Asst. U.S. Attorney, Lexington, KY, Michael J. Salem, Trial Attorney, U.S. Department of Justice Tax Division, Kenneth W. Rosenberg (argued and briefed), U.S. Department of Justice Appellate Section Tax Division, Kenneth L. Greene (briefed), Department of Justice, Washington, DC, for Defendants-Appellees.