Beyond 1040: Six Sources of Evidence on Lost Earnings

/ / CFES Publications, Economic Damages in Personal Injury Litigation

by Chad L. Staller, MBA, JD, MAC

A plaintiff’s tax returns are generally the primary source of evidence on the extent of lost past and future income in a personal injury or wrongful death matter, but other records and evidence may clarify and augment the loss analysis. Consider these sources when preparing a damages case:

  1. Lifetime annual income records, available from the Social Security Administration by filing form SSA-7050-F4:
  2. Employers’ personnel files, which can show a wealth of information on the plaintiff’s current and probable future income.
  3. Collective bargaining agreements can provide detailed data on the compensation of union members.
  4. The Bureau of Labor Statistics maintains data on compensation in many fields.
  5. Trade associations can often provide information on wages.
  6. Headhunters and employment agencies might provide wage and income data for various specialized occupations.

These sources of information can assist in analyzing actual loss and help guide further discovery.

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