Disposition of Installment Obligations by an Estate or Trust

Abstract

<p>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.^{<strong>1 </strong>}Usually, that question is raised with estates (or trusts) as to installment obligations entered into before death, which involves “income in respect of decedent”,^{<strong>2 </strong>}for installment obligations transferred in whole or in part at death to an obligor (or the obligor) under the installment contract^{<strong>3 </strong>}or for installment obligations cancelled at death.^{<strong>4</strong>}</p>