Rodger Powell owns all the stock in Fireside Bar and Grill Corporation in Pittsburgh. Now that he has turned 65, Rodger wants to sell his business and retire to sunny Florida. Karin Godfrey, a long-time bartender at Fireside, offers to purchase all the corporation’s noncash assets in exchange for a 25% down payment, with the remaining 75% paid in five equal annual installments. Interest will accrue at a market rate on the unpaid installments. Rodger plans to liquidate the corporation that has operated the Bar and Grill. He also plans to have Fireside Bar and Grill distribute the installment notes and any remaining assets. What tax issues should Fireside Bar and Grill, Rodger, and Karin consider with respect to the proposed purchase?