Although no reported authority is on point, it is reasonably clear
that a tortfeasor should not incur COD income from compromise
of a final judgment of damages for a personal injury, again because
the tortfeasor has received no loan proceeds.7 8 If it is argued that
the tortfeasor may have enjoyed the pleasure of speeding, or a valuable
saving of time, it may be answered that neither type of benefit
is taxable under any circumstances, and so their exclusion from
income was not caused by an offsetting debt.79 The requirement of