Last year Salvador sold a tract of land (basis of $1 million) to Kate (an unrelated party) for $4 million, with a cash down payment of $1 million and notes for the balance. The notes carry a 3.5% rate of interest and mature annually at $1 million each over three years.
Salvador did not elect out of the installment method. Before any of the notes mature and when they have a fair market value of $2.8 million, Salvador dies and the notes pass to his estate. The executor sells the notes for their fair market value. What is the Federal estate and income tax result?