- 6 - grievances against CWU in addition to the grievance that pertained to his shoulder injury. Petitioner's own testimony shows that these four grievances were not filed on account of physical injury but instead were filed because petitioner claimed that he was being subjected to unfair labor practices. We find that he has failed to prove that any of these four grievances were tort type claims for personal injuries. From this record, we cannot determine the amount, if any, of the settlement payment allocable to tort type claims for personal injuries. The agreement contains broad language relieving CWU from liability, and the settlement agreement does not specifically allocate any portion of the amount paid to petitioner's shoulder injury. Under these circumstances, we hold that the payment from CWU is not excludable from petitioner's 1993 gross income. See Taggi v. United States, 35 F.3d 93, 96 (2d Cir. 1994). 2. Schedule C Deductions After leaving CWU, petitioner engaged in an activity known as "Total Video". The purpose of this activity was to produce videos. On the Schedule C attached to his 1993 Federal income tax return, petitioner claimed the following deductions with respect to the video activity:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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