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Contact Structured Sales Expert John Darer®

  • Call 203-325-8640 or email
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Want Structured Settlement Quotes Now?

  • Structured Settlement Quotes Form (Secure Form)
    Click Here If You Are Currently a Party to a Personal Injury or Wrongful Death Law Suit or representing, or insuring one of the parties. This link is NOT intended for people who already have structured settlements. You can also use this form to request more information or get quotes for structured attorney fees, employment related structured settlements, structured oil & gas lease bonus payments, structured celebrity endorsement fees, structured property installment sales, structured business installement sales, structured real estate commissions, jackpots and lotteries and other opportunities to use a non qualified assignment Questions? Call John Darer at 888-325-8640

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Structured Sale...Tax Basis for The Stuctured Sale

  • Treas. Reg. 1.451-2(a), Commissioner v. Tyler, 28 B.T.Z. 367 (1933)-Deals with avoidance of constructive receipt
  • Wynne v. Commissioner, 47 B.T.Z. 731 (1942), Cunningham v. Commissioner, 44 T.C. 103 (1965), acq., 1966-2 C.B.4 Case law supporting substitution of obligors
  • Revenue Ruling 75-457 and Revenue Ruling 82-122 which allow substitution of obligors
  • IRC 453-Tax Code section supporting disposition of property via installment sales

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