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Links & Reference Materials

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Internal Revenue Code Section 104(a)
Tax-free status of personal physical injury cases.

Internal Revenue Code Section 130
The process and tax treatment of assigning the  future payment obligation to a third party.

Internal Revenue Code Section 5891
Regulations on the process for transferring future structured settlement periodic payments to another party.

Internal Revenue Procedure 93-34
The allowability for individuals to structure their settlements from a qualified settlement fund (QSF) (468B).

Revenue Ruling 79-220
IRS ruling stating that as long as procedure under Section 104(a)(2) is followed, periodic payments are tax-free to the recipient.

Childs v. Commissioner
Deferral of the payment of attorney fees through a structured settlement are not taxable income until the year received.  Childs v. C.I.R., 103 T.C. 634, U.S.Tax Ct.,1994, Nov. 14, 1994.


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