- 2 - $200,000 settlement amount (settlement amount at issue) that petitioner received in 1997 in settlement of a claim is excludable under section 104(a)(2)2 from petitioner’s gross income for that year. We hold that $120,000 is excludable and that $80,000 is not. FINDINGS OF FACT Most of the facts have been stipulated and are so found. At the time petitioner filed the petition in this case, he resided in Minneapolis, Minnesota. During 1997, petitioner was employed as a television camera- man. In that capacity, on January 15, 1997, petitioner was operating a handheld camera during a basketball game between the Minnesota Timberwolves and the Chicago Bulls. At some point during that game, Dennis Keith Rodman (Mr. Rodman), who was playing for the Chicago Bulls, landed on a group of photogra- phers, including petitioner, and twisted his ankle. Mr. Rodman then kicked petitioner. (We shall refer to the foregoing inci- dent involving Mr. Rodman and petitioner as the incident.) 1(...continued) A, Itemized Deductions, and $7,178 of deductions claimed by petitioner in Schedule C, Profit or Loss From Business. There are other determinations in the notice that are computational in that resolution of the issues relating to such determinations flows automatically from our resolution of the issue addressed herein. 2All section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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