Other courts have noted this distinction in upholding the taxation not only of wages, but also of personal gain derived from "other" sources, recognizing some limitation to the reach of income taxation. For example, in "Conner v. United States", 303 F. Supp. 1187 (S.D. Tex. 1969), "aff'd in part and rev'd in part", 439 F.2d 974 (5th Cir. 1971), a couple had lost their home to a fire, and had received compensation for their loss from the insurance company, partly in the form of hotel costs reimbursed. The court acknowledged the authority of the IRS to assess taxes on all forms of payment, but did not permit taxation on the compensation provided by the insurance company, because unlike a wage or a sale of goods at a profit, this was not a gain. As the Court noted, "Congress has taxed income, not compensation".