[Fredslist] Tax Consequences for Stuctured Settlements

[Philip J Smallman Esq.]

Dear Gotham
I represent a client was had agreed to settle a "Wrongful Conviction" claim against the State of New York for 22 years of wrongful incarceration. He is agreeing to have a portion of the settlement fund an annuity. He also wishes to take the balance of the settlement in a cash payout for his own purposes and conventional investing. There is some dispute regarding the tax consequences of 
1 The overall settlement 
2 The tax advantage, if any, of taking a greater amount in annuity 
3 The tax consequences of NOT doing an annuity now and only doing one at some point in the future. 
Thanks for any leads 
Phil Smallman

PJFS