The ABC partnership operates a hotel and has the following balance sheet:

Assets Partners Capital

A.B. F.M.V. A.B. F.M.V.

Hotel (no recapture) $30,000 $300,000 A $38,000 $150,000

Furniture (all gain is

1245) 30,000 90,000 B 38,000 150,000

Inventory (prod-

Ucts sld by hotel

Shops) 54,000 60,000 C 38,000 150,000

$114,000 $450,000 $114,000 $450,000

Disregarding any application of 483 and 1274, what are the tax consequences to A if he sells his interest for $150,000, to be paid $50,000 per year over three years? A does not use 453(d) to elect out of 453 treatment.