<P> In Central Illinois Public Service Co. v. United States, 435 U.S. 21 (1978), the U.S. Supreme Court confirmed that wages and income are not identical as far as taxes on income are concerned, because income not only includes wages, but any other gains as well . The Court in that case noted that in enacting taxation legislation, Congress "chose not to return to the inclusive language of the Tariff Act of 1913, but, specifically,' in the interest of simplicity and ease of administration,' confined the obligation to withhold (income taxes) to' salaries, wages, and other forms of compensation for personal services"' and that "committee reports...stated consistently that' wages' meant remuneration' if paid for services performed by an employee for his employer"'. </P> <P> Other courts have noted this distinction in upholding the taxation not only of wages, but also of personal gain derived from other sources, recognizing some limitation to the reach of income taxation . For example, in Conner v. United States, 303 F. Supp. 1187 (S.D. Tex. 1969), aff'd in part and rev'd in part, 439 F. 2d 974 (5th Cir. 1971), a couple had lost their home to a fire, and had received compensation for their loss from the insurance company, partly in the form of hotel costs reimbursed . The court acknowledged the authority of the IRS to assess taxes on all forms of payment, but did not permit taxation on the compensation provided by the insurance company, because unlike a wage or a sale of goods at a profit, this was not a gain . As the Court noted, "Congress has taxed income, not compensation". </P> <P> By contrast, other courts have interpreted the Constitution as providing even broader taxation powers for Congress . In Murphy v. IRS, the United States Court of Appeals for the District of Columbia Circuit upheld the federal income tax imposed on a monetary settlement recovery that the same court had previously indicated was not income, stating: "(a) lthough the' Congress cannot make a thing income which is not so in fact,'...it can label a thing income and tax it, so long as it acts within its constitutional authority, which includes not only the Sixteenth Amendment but also Article I, Sections 8 and 9 ." </P> <P> Similarly, in Penn Mutual Indemnity Co. v. Commissioner, the United States Court of Appeals for the Third Circuit indicated that Congress could properly impose the federal income tax on a receipt of money, regardless of what that receipt of money is called: </P>

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