Litigation

The IRS recently disallowed a doctor's deduction for "professional insurance premiums" paid to an offshore entity and then recovered by him through a home equity loan. The decision was sustained by the Tax Court which also held that he had unreported income.  Fraud penalties were also imposed.  So what does this have to do with structured settlements and structured attorney fees in particular?

• Well the doctor's name was "Child", and ithe abbreviated case style " Child v Commissioner. 

Cite: Douglas D. Child et ux. v. Commissioner; T.C. Memo. 2010-58; Docket No. 11021-06; IRC Secs. 162 ; 163(h)(3) ; 446(b) ; 6663 .

• On the other hand the seminal case for structured attorney fees is the compeltely unrelated  Childs v Commissioner:

Cite: Richard A. Childs et al. v Commissioner of Internal Revenue 103 T.C. No. 36 Docket No. 15639-92

We live in a world where even one letter in a sound byte has the potential to create confusion. Thus I've chosen to frame the difference in the form of a lyric...

One Doctor Don't Stop No Show  (loosely to the Tune of "One Monkey Don't Stop No Show" By The Honey Cone)

Cash Flow Must Go On..

Oh, One Doc-tor

Don't Stop No Show

If You Rip Off The Gov.

You're a Ho, You're a Schmo, You doe-doe

See The "CHILDS Case"

Is The Ace in The Hole

To struct-ure att-or-ney fees

"CHILD", It Don't Mean a Hill of Beans.

So Struct-ure

Att-or-ney Fees

De-fer-ral  my bud!

If You Please, If you Please If You Please

One Doc-tor Don't Stop No Show  (to fade)

This author, John Darer is a Registered Settlement Planner and an expert in structured attorney fees. With the end of year approaching attorneys should learn more about how structuring their fees can benefit them. 

More information on structured attorney fees