id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-429	Germain, Gregory L.	Avoiding Phantom Income in Bankruptcy: A Proposal for Reform	2022	49	.pdf	application/pdf	24533	1199	56	Thus, the reference in the regulations to the general rules governing cash method deductions suggests that no deduction would be available for a cash method taxpayer's payments to a QSF, because under the cash method no deduction is allowed for fund payments unless the taxpayer's underlying liability to the creditor is discharged as a result of the transfer. The preamble to the new (1999) proposed section 468B regulations suggest that additional room exists for section 46 1(f) disputed payment funds: The proposed regulations provide rules relating to the taxation of amounts transferred to an escrowee, trustee, or court in connection with a contested liability within the meaning of section 461(f) (i.e. a transfer to a 461(f) fund).	cache/ftr-429.pdf	txt/ftr-429.txt