Content reviewed October 17, 2026 · Educational reference
Every Code section, regulation, ruling, PLR, and case that establishes, supports, and constrains the Structured Installment Sale — with the citation, what it says, and how it applies.
A Structured Installment Sale is not a creature of any single statute. It is an installment sale under IRC §453 in which the buyer's deferred-payment obligation is assigned, at or before closing, to a third-party assignment company that funds the payment stream with an annuity. Its legal validity rests on three independent pillars, each governed by its own body of authority. For each authority below you'll find the citation, what it says, and how it applies to the SIS.
| Pillar | Question it answers | Primary authorities |
|---|---|---|
| 1 · Installment treatment | Does the sale qualify to spread gain over the years payments are received? | IRC §453 (incl. §453(f)(3)); Reg. §15a.453-1; §453A; §453B |
| 2 · The co-obligor assumption | Can an assignment company assume the buyer's obligation as co-obligor (the authorities approve even full substitution) without triggering gain? | IRC §453B; Rev. Rul. 75-457; Rev. Rul. 82-122; Cunningham |
| 3 · No constructive receipt | Has the seller avoided being treated as already in receipt of the money? | Reg. §1.451-2; Oden; Williams |
Sources: IRC §453 — installment method; Treas. Reg. §15a.453-1; IRC §453B — dispositions of obligations; T.D. 8675 — debt modifications, IRS Bulletin 1996-29; PLR 201248008 — ESOP-related restructuring; nonprecedential.
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