id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-477	Kahn, Douglas A.	Compensatory and Punitive Damages for a Personal Injury: To Tax or Not to Tax?	2022	58	.pdf	application/pdf	26219	1255	57	Punitive damages are a windfall that increases the recipient's wealth.91 All accretions to wealth should be taxed unless there is a compelling policy reason not to do so, and no such reason exists as to punitive damages. HISTORY A. Generally The Treasury initially took the position that damages received for personal injury are gross income, analogizing them to the proceeds of accident insurance, which the Treasury assumed to be taxable.6 However, in 1918, the Attorney General issued an opinion concluding that accident insurance proceeds are not taxable because they constitute a kind of conver- sion of human capital caused by the injury.7 As a consequence of the Attorney General's opinion, the Treasury promptly revoked the regulation that declared personal injury damages to be taxable, holding instead that an 6.	cache/ftr-477.pdf	txt/ftr-477.txt