Robert W. Wood (Robert W. Wood, P.C., San Francisco) has published Structured Settlements and Factoring: Never the Twain Shall Meet?, also available on the Tax Analysts web site as Doc 2005-4839, 2005 TNT 46-98. Here is the abstract:
Robert W. Wood discusses tax issues, particularly the possible imposition of the section 5891 excise tax, raised by the use of factoring to finance structured settlements.



