Eugene Amos (plaintiff) was working as a cameraman at a professional basketball game. During the game, Dennis Rodman, one of the players, fell onto Amos and kicked him in the groin. Amos reported a shooting pain in his neck and a limp when he walked. At the time, Amos was on pain medication for preexisting back pain and refused any more medication. Without being discharged, Amos left the hospital where he was seeking medical treatment. Amos sought the advice of a lawyer and reached a settlement with Rodman. Under the settlement agreement, Amos was to receive $200,000 for the release of any claims that he had against Rodman. Pursuant to confidentiality provisions in the agreement, the money would also prevent Amos from disclosing information about the settlement or incident or assisting in any criminal prosecution against Rodman. The settlement agreement contained a liquidated-damages clause that entitled Rodman to $200,000 if Amos breached any of the confidentiality provisions. Amos excluded the $200,000 settlement payment from his gross income. The commissioner of internal revenue (commissioner) (defendant) determined that only a nominal amount of the settlement payment could be excluded from Amos’s gross income. Amos petitioned the United Stated Tax Court for a redetermination.