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inconsistent with the notion that security concerns may in fact
have motivated the transactional form chosen: “GIA sells real
property to low-income families in Western Georgia near Columbus.
Because these families are poor and have little or no credit
history the properties are sold using a ‘Contract for Deed’”.
Hence, we hold that these instruments upon their execution
effected a completed sale for Federal tax purposes. Petitioners’
reliance on Hambrick v. Bedsole, 91 S.E.2d 205 (Ga. Ct. App.
1956), and on the voidability of their agreements, in support of
a contrary conclusion, is misplaced.
Hambrick v. Bedsole, supra at 208-209, involved a contract
under which title to property was not to pass and possession was
not to be delivered until the full, lump-sum purchase price was
paid. The agreement did not provide for either a downpayment or
installment payments. See id. The court decided that the
contract “was a mere executory agreement to sell and did not
constitute a sale”, on the grounds that the buyer “gained by the
contract neither title to, nor the right of possession of” the
subject property. Id. at 209. The situation in Hambrick v.
Bedsole, supra, thus bears almost no resemblance to that in the
instant case and cannot inform our analysis.
As regards the voidability of the contracts for deed, we see
no material difference between the provisions on default here and
those contained in the agreement in Chilivis v. Tumlin Woods
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