Read 51 T.C. 1049 and answer each of the questions:

a.What is the correct citation for the case?

b.What is (are) the main tax issue(s) addressed in the case?

c.What was the courts holding in the case?

2.Read the analysis in GCM 39584 and answer each of the questions:

a.What is the correct citation for the memo, including publication date?

b.Prior to 51 T.C. 1049, what was the position of the IRS as to whether the assignment of an installment obligation constituted a disposition of the obligation for gain recognition purposes under 453B??