PLR-140012-08: "Service Rules on Tax Treatment of Real Estate Interest Sale"

In PLR-140012-08, the IRS has reached a decision on the income tax treatment of a taxpayer's real estate interest sale. The Service has found that the section 453(e)(1) with regard to related party provisions do not apply and that section 453(g) will not preclude the taxpayer's use of the installment method. Furthermore the Service has determined when the taxpayer will recognize unrecaptured section 1250 claim.