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Structured Sale...Tax Basis for The Stuctured Sale

  • Treas. Reg. 1.451-2(a), Commissioner v. Tyler, 28 B.T.Z. 367 (1933)-Deals with avoidance of constructive receipt
  • Wynne v. Commissioner, 47 B.T.Z. 731 (1942), Cunningham v. Commissioner, 44 T.C. 103 (1965), acq., 1966-2 C.B.4 Case law supporting substitution of obligors
  • Revenue Ruling 75-457 and Revenue Ruling 82-122 which allow substitution of obligors
  • IRC 453-Tax Code section supporting disposition of property via installment sales

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