Citation Codes Equivalent Citations citation codes Docket Number No. 06-70623. Advocates Robert L. Allum, Belgrade, MT, for Petitioner-Appellant. John A. Nolet, Esq., U.S. Department of Justice Tax Division, Washington, DC, for Respondent-Appellee. Judges Susan Graber Richard R. Clifton Carlos T. Bea Acts Internal Revenue Code — Income Taxes — Normal Taxes And Surtaxes — Computation Of Taxable Income — Items Specifically Excluded From Gross Income — Compensation For Injuries Or Sickness Internal Revenue Code — Procedure And Administration — Judicial Proceedings — Court Review Of Tax Court Decisions — Courts Of Review See more information ... Smart Summary Please sign up to generate summary. OPINION Robert L. ALLUM, Petitioner — Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent — Appellee. MEMORANDUM This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3. Robert L. Allum appeals pro se from the tax court's judgment holding that receipt of income pursuant to a settlement agreement was not excludable from taxable income pursuant to 26 U.S.C. § 104(a)(2). We have jurisdiction pursuant to 26 U.S.C. § 7482. We review a tax court's legal conclusions de novo and its findings of fact for clear error. DHL Carp. Subsidiaries v. CIR, 285 F.3d 1210, 1216 (9th Cir. 2002). We affirm. The tax court properly determined that the settlement Allum received was not excludable from his taxable income because it was received as settlement for violation of his civil rights, not physical injury or sickness. See 26 U.S.C. § 104(a)(2); Comm'r v. Schleier, 515 U.S. 323, 329-30, 115 S.Ct. 2159, 132 L.Ed.2d 294 (1995). The tax court also properly determined that the money Allum paid to his attorney in connection with negotiating the settlement was not excludable under section 104(a)(2). See Comm'r v. Banks, 543 U.S. 426, 430, 125 S.Ct. 826, 160 L.Ed.2d 859 (2005). Allum's remaining contentions are unpersuasive. AFFIRMED.