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
Harl, Neil E.
"Disposition of Installment Obligations by an Estate or Trust,"
Agricultural Law Digest: Vol. 17
, Article 1.
Available at: https://lib.dr.iastate.edu/aglawdigest/vol17/iss13/1