26 C.F.R. § 1.468B-4
Taxability of distributions to claimants
Whether a distribution to a claimant is includible in the claimant's gross income is generally determined by reference to the claim in respect of which the distribution is made and as if the distribution were made directly by the transferor. For example, to the extent a distribution is in satisfaction of damages on account of personal injury or sickness, the distribution may be excludable from gross income under section 104(a)(2). Similarly, to the extent a distribution is in satisfaction of a claim for foregone taxable interest, the distribution is includible in the claimant's gross income under section 61(a)(4).
Notes of Decisions
Cited in 1
case, 2017–2017 · leading case: Ritter v. Comm'r, 114 T.C.M. 352 (Tax Ct. 2017).
Ritter v. Comm'r, 114 T.C.M. 352 (Tax Ct. 2017). “, whether a distribution from a designated settlement fund, like the QSF, is includible in a payee's gross income is generally determined by reference to the claim in respect of which the distribution is made and as if the distribution were made directly to the payee by the…”
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