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Section 15a.453-1(c), Temporary Income Tax Regs., supra,
provides installment sale treatment for "contingent payment
sales". A "contingent payment sale" is "a sale or other
disposition of property in which the aggregate selling price
cannot be determined by the close of the taxable year in which
such sale or other disposition occurs." Id. Where the sales
agreement provides for no maximum aggregate selling price but
fixes the period over which payments may be received, the
temporary regulations generally require the seller to allocate an
equal portion of its basis in the sale property to each of the
taxable years in which payments may be received. Sec.
15a.453-1(c)(3), Temporary Income Tax Regs., 46 Fed. Reg. 10714
(Feb. 4, 1981). The seller computes its income for each year in
respect of a contingent payment sale as the excess of the
payments received in that year over the portion of the basis
allocated to that year. Id.
The temporary regulations anticipate that application of the
general rule for basis recovery will create distortions of income
in some cases, and they provide certain remedies. The
Commissioner may require an alternate method of basis recovery if
the Commissioner finds that the general rule will "substantially
and inappropriately accelerate recovery of basis." Sec. 15a.453-
1(c)(7)(iii), Temporary Income Tax Regs., 46 Fed. Reg. 10716.
Conversely, if application of the general rule "will
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