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In Molzof v. United States, 502 U.S. 301, 116 L. Ed. 2d 731, 112 S. Ct. 711 (1992), the Court held that the only 'punitive damages' barred by the FTCA are those 'legally considered 'punitive damages' under traditional common-law principles,' namely damages based on plaintiff's intentional misconduct. Id. at 312. A failure to deduct taxes from lost future earnings does not amount to 'punitive damages,' as the Supreme Court has now defined it. See, e.g., Palmer v. United States, 146 F.3d 361, 367 (6th Cir. 1998); Manko v. United States, 830 F.2d 831, 837 (8th Cir. 1987); Ferrarelli v. United States, 1992 U.S. Dist. LEXIS 22702, 90 Civ. 4478, 1992 WL 893461, at *9-11 (E.D.N.Y. September 24, 1992). 

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