Murphy v. IRS
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Marrita Murphy and Daniel J. Leveille, Appellants v. Internal Revenue Service and United States of America, Appellees (commonly known as Murphy v. IRS),[1] is a tax case in which the United States Court of Appeals for the District of Columbia Circuit originally held that the taxation of emotional distress awards by the federal government is unconstitutional. That decision was vacated, or rendered void,[2] by the Court on December 22, 2006. The Court eventually overturned its original decision, finding against Murphy in an opinion issued on July 3, 2007.[3]
Murphy v. IRS | |
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Court | United States Court of Appeals for the District of Columbia Circuit |
Full case name | Marrita Murphy and Daniel J. Leveille v. Internal Revenue Service and United States of America |
Argued | February 24, 2006 |
Reargued | April 23, 2007 |
Decided | August 22, 2006 |
Citation(s) | 460 F.3d 79 (D.C. Cir. 2006) 2006-2 U.S. Tax Cas. (CCH) ¶ 50,476 2006 WL 2411372 |
Case history | |
Prior history | 362 F. Supp. 2d 206 (D.D.C. 2005) |
Subsequent history | Vacated on rehearing, 493 F.3d 170 (D.C. Cir. July 3, 2007), 2007-2 U.S. Tax Cas. (CCH) ¶ 50,531; Rehearing en banc denied, September 14, 2007. |
Court membership | |
Judge(s) sitting | Douglas H. Ginsburg, Judith Ann Wilson Rogers, Janice Rogers Brown |
Case opinions | |
Majority | Ginsburg, joined by Rogers, Brown |
Laws applied | |
The July 3, 2007 decision was that the taxpayer's recovery could be taxed under Article I, Section 8 of the Constitution even if the recovery were not "income" under the Sixteenth Amendment. The Court conceded that this rationale for granting a rehearing and overturning the original decision was not in the government's original appeal, and would not normally have been considered under the Court's rules. The Court indicated that the issue was of such importance, affecting "the broad public interest", that the new argument could be entertained.