For transactions involving farm and ranch property, installment sales are common1 and installment sales between related persons are almost as common.2 A 2009 private letter ruling3 has cast light on both of the related person rules for installment sales4 and on the recapture consequences of such transactions.5 The two provisions governing related person transactions with respect to installment transactions are quite different and require careful planning if adverse income tax consequences are to be avoided.



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