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$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.
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