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client of mine has this.. it can be confusing.. my client is getting paid over time on the buyout. i have a 6252 installment sale form populated and that kicks off interest income and installment sale gain.. mine is all gain as there was no basis

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Posted

Like many tax issues, it depends on the facts and circumstances.  The concern is whether the income is capital or ordinary.

What exactly is the client selling?  if he/she is selling a future stream of income, based on present value calculations, it is ordinary income under the "substitute-for-ordinary income doctrine."   The courts have applied that doctrine to the sale of rights to lottery winnings.

If on the other hand, the taxpayer is selling a perpetual easement with exclusive rights to the land the tower sits on, that is the sale of a capital asset.

 

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