I have an assignment where I have to give responses on the article below the requirements for the responses are designed to expand the topics, "includes some new details on that topic below. can you please include the references of the new sources in citation format?
The article \"Monetized Installment Sales Make the IRS "Dirty Dozen" List for the Second Straight Year" examines the inclusion of monetized installment sales on the Internal Revenue Service's annual "Dirty Dozen" tax schemes list, which cautions taxpayers to potentially unfair tax arrangements (And rew, 2023). Monetized installment sales are advertised as a way to collect the entire profits from the sale of a highly valued asset while delaying the appropriate tax payment for an indefinite period of time. The article describes the basic steps of a generic monetized installment sale, in which a seller sells property to a promoter in return for a thirty-year payment note. The promoter then sells the property to the buyer and enters into a nonrecourse loan agreement with an intermediary to lend the seller 95 percent of the sales profits. Under the installment sale requirements of Section 453, the seller contends that revenue earned under the installment note will only be reflected in income when acquired in the future. The IRS, on the other hand, views monetized installment sales to be potentially harmful and has cited various reasons why they may not perform as stated. According to the IRS, the intermediary loan is unsecured and nonrecourse, thus creating taxable income to the seller upon receipt. Furthermore, if the loan is secured by cash escrow, it breaches the economic benefit principle of section 453. Furthermore, the 2012 IRS Memorandum, which is often cited by marketers, is factually distinct from ordinary monetized installment sale deals, The IRS Memorandum was limited to agricultural property transactions and did not need a middleman to purchase the property from the seller (Andrew, 2023). The inclusion of monetized installment purchases on the lRS's "Dirty Dozen" list, as well as the recent issue of a Chief Counsel Advice (CCA). show the IRS's scrutiny of these transactions. To dispute these arrangements, the IRS may use additional authorities or common law theories, such as economic substance (Andrew, 2023). The newly established Office of Promoter Investigations will most likely target promoters and taxpayers involved in monetized installment sales. It is recommended that taxpayers considering or who have completed a monetized installment sale contact with an independent tax specialist to gain insight into the legal requirements and technical analyses underpinning such arrangements. Thus, corrective efforts may be performed to reduce the likelihood of negative repercussions and significant tax fines. Refe re nces Andrew Mirisis. (2023, January 31). Monetized installment sales make the IRS \"Dirty Dozen" List for the second straight year. JD Supra. https://www.jdsupra.com/legalnews/monetize d-installment-sa|es-make-the-7967126/
