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  • Murphy v. Internal Revenue ServiceMurphy v. Internal Revenue Service
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Murphy v. Internal Revenue Service

Unites States Court of Appeals for the District of Columbia
493 F.3d 170 (2007)


Marrita Murphy (plaintiff) was unlawfully fired from her job at the New York Air National Guard (NYANG) after reporting environmental hazards to state authorities. Murphy filed a retaliation claim against NYANG with the Department of Labor (DOL). At the administrative hearing, Murphy testified to her physical and emotional damages. The DOL awarded Murphy $45,000 for emotional distress and $25,000 for injury to reputation. Murphy initially included the $70,000 award as income and paid taxes on it. Murphy later filed an amended return, seeking reimbursement of the taxes paid on the $70,000 award. The Internal Revenue Service (IRS) (defendant) denied reimbursement. Murphy brought suit in federal district court against the IRS and the United States government (defendant). The district court ruled in favor of the defendants. Murphy appealed to the United States Court of Appeals for the District of Columbia. The court of appeals reversed, holding that the award was not income and was not subject to taxation. The government petitioned for an en banc rehearing, and the court of appeals granted the petition.

Rule of Law


Holding and Reasoning (Ginsburg, C.J.)

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