Comment on FR Doc # 2010-00168

We are writing to submit our outline for oral comments on the recently proposed Treasury Regulation Section 1.104-1 (the “Proposed Regulations”). We believe that Section 104(a)(2) is too limiting when dealing with the application to damages for “personal physical injury or physical sickness” with taxpayers who are victims of sexual abuse or harassment, and victims of long-term wrongful imprisonment. Our outline is attached.