With several exceptions, the rule is clear that the privilege of income deferral by installment reporting of gain is personal to the seller and cannot be transferred to another taxpayer.¹ Usually, that question is raised with estates (or trusts) as to installment obligations entered into before death, which involves “income in respect of decedent”,² for installment obligations transferred in whole or in part at death to an obligor (or the obligor) under the installment contract³ or for installment obligations cancelled at death.⁴