Eagle and Hill Corporations discuss the terms of a land sale, and they agree to a price of $230,000. Eagle wants to use the installment sale method, but is not sure Hill is a reliable borrower. As a result, Eagle requires Hill to place the entire purchase price in escrow to be released in five yearly installments by the escrow agent. Is the installment method available to Eagle?
A partial list of research sources is:
• Rev. Rul. 77-294, 1977-2 C.B. 173
• Rev. Rul. 79-91, 1979-1 C.B. 179
• H. O. Williams v. U.S., 46 AFTR 1725, 55-1 USTC ¶9220 (5th Cir., 1955)