Litigation

The watershed moment that Hindert describes concerning Richard B. Risk's linkage between IRC 468B and IRC 5891 exposes their selective logic.

If the gravamen of the argument concerning single claimant 468B qualified settlement funds is that the "one or more claims" literally means "one or more" and not more than one, THEN logically when the Internal Revenue Code says the definition is "for the purposes of this section" doesn't it literally mean solely for the purposes of this section? That is to say this limited section of the Internal Revenue Code  entitled structured settlement factoring transactions", which begins at IRC 5891(a) with "There is hereby imposed on any person who acquires directly or indirectly structured settlement payment rights in a structured settlement factoring transaction a tax equal to 40 percent of the factoring discount as determined under subsection (c)(4) with respect to such factoring transaction." (i.e. the section simply imposes an excise tax and describes conditions for exceptions to the tax)

Are settlement planners supposed to be "selectively logical"?  So much gum flapping has been done on this subject that it could be an alternative energy source.