For decades, taxpayers have tried various strategies for selling land, qualifying the transaction for installment reporting of the gain with the land then resold to a third party for cash. Often, the initial transaction involved related parties with the resale typically made to a developer who paid cash and received title to the property. The result of the two stage transaction, if successful, was to have the initial buyer in possession of the full purchase price with the initial buyer making payments to the initial seller who reports the gain over the period of the installment obligation.

The IRS has issued proposed regulations which simplify the computation of depreciation by allowing taxpayers to group assets in one or more general asset accounts with the assets in any particular asset account depreciated as a single asset. The regulations apply to assets placed in service in taxable years ending on or after the date of publication of the final regulation. For prior taxable years, the IRS indicated that it will allow use of any reasonable method that clearly reflects income and is consistently applied to the general asset accounts.