Notes
Abstract
Questions of characterization can often be overlooked when navigating through the complexities of our modern tax law and may become a pitfall for the unwary. A lack of clarity towards characterization has the potential to create highly litigated areas within our law that could put additional burdens upon judicial resources. The characterization of settlement payments arising under the False Claims Act has the potential to create such a problem. However, by adopting a predictable framework this problem may be avoided.