Chen C. and Victoria R. Wang, et al. - Page 19

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          Reconciliation Act of 1987 (the 1987 Act), Pub. L. 100-203, sec.            
          10202, 101 Stat. 1330-388, repealed section 453C for sales after            
          December 31, 1987.  However, the 1987 Act created section 453(l),           
          which contains language nearly identical to that found in section           
          453C concerning the denial of installment sales treatment for               
          dealer dispositions, with an exception for sales of residential             
          lots.  See 1987 Act sec. 10202(b)(2), 101 Stat. 1330-388.  Thus,            
          in repealing section 453C and enacting section 453(l), Congress             
          did not alter the treatment for installment obligations arising             
          from the sale of residential lots.  H. Conf. Rept. 100-495 at 927           
          (1987), 1987-3 C.B. 193, 207.                                               
               Respondent has not issued regulations in connection with               
          section 453(l) but previously had issued temporary regulations              
          for the now-repealed section 453C.  Since the relevant language             
          in section 453(l) is identical to that used in section 453C, we             
          turn to the regulations under section 453C for guidance in                  
          interpreting the term "residential lots" contained in section               
          453(l)(2)(B).                                                               
               Section 1.453C-8T(4), Temporary Income Tax Regs., 53 Fed.              
          Reg. 34725 (Sept. 8, 1988), defines a residential lot as "a                 
          parcel of unimproved land upon which the purchaser intends to               
          construct (or intends to contract to have another person con-               
          struct) a dwelling unit for use as a residence by the purchaser."           
          Petitioner argues that the land sold by EIC was zoned such that a           





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