In the case of David H. Baral v. United States, 1999, the Supreme Court addressed whether a portion of an attorney's fees award could be considered income under federal tax law. The court ruled in favor of the U.S., stating that all parts of any legal settlement are to be included as gross income unless explicitly excluded by law. This ruling was based on Section 61(a) and (b) of Internal Revenue Code which defines gross income as "all income from whatever source derived." In this particular case, Baral had received a $500,000 settlement in a lawsuit against his former employer for wrongful termination and defamation; however he argued that part of it should not be taxed because it went directly towards paying his lawyers' fees. The Supreme Court disagreed with this argument and affirmed that such amounts must also be counted as taxable income.

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