Litigation

This author submits that certain settlement planners thought that Treasury guidance on the Single Claimant 468B qualified settlement fund was a forgone conclusion given that it was on the Priority Guidance plan for so many years. Then it was omitted from the 2009-2010 guidance plan without explanation. The settlement planners panicked and obviously came up with a strategy to attempt to shoe horn it into a hearing on proposed regulations relating to the exclusion from gross income for amounts received on account of personal physical injuries or physical sickness, which is  a bit of a non sequitur.

Humming a few bars to the tune of "Panic" by The Smiths

Panic on the streets of Portland  Panic on the streets of Washington

On September 15, 2009 The IRS issued notice of proposed rulemaking. The notice stated that the agency sought comments, to wit

"Comments and Requests for a Public Hearing
Before these proposed regulations are adopted as final regulations, consideration will be given to any
written (either a signed paper original with eight (8) copies) or electronic comments that are submitted timely to the IRS. The IRS and the Treasury Department specifically requests comments on the clarity of the proposed rules and how they can be made easier to understand. All comments will be available for public inspection and copying.

A public hearing will be scheduled if requested in writing by any person that timely submits written comments. If a public hearing is scheduled, notice of the date, time and place for the hearing will be published in the Federal Register".

What I want to know is just one day after doing a fantastic job of keeping people focused on what is actually on the table, Jeremy Babener is throwing his QSF paper into the "kitchen sink"?

(1) Can't these people stay on point? (2) Let the QSF issue stand on its own, with its own hearing.