By contrast, other courts have interpreted the Constitution as providing even broader taxation powers for Congress. In "Murphy v. IRS", the United States Court of Appeals for the District of Columbia Circuit upheld the federal income tax imposed on a monetary settlement recovery that the same court had previously indicated was not income, stating: "lthough the 'Congress cannot make a thing income which is not so in fact,'... it can "label" a thing income and tax it, so long as it acts within its constitutional authority, which includes not only the Sixteenth Amendment but also Article I, Sections 8 and 9."