Sales of Property Outside Section 453

64 Taxes 153 (1986)

13 Pages Posted: 6 Sep 2009

See all articles by Dennis S. Karjala

Dennis S. Karjala

Arizona State University College of Law

Date Written: 1986


When the installment sale provisions of the Internal Revenue Code apply to a casual sale of property, both the timing of taxation and the amount of gain that must be included in gross income in each year are fairly clearly and objectively determined. When those provisions do not apply, however, both analytical theory and tax practice are in a state of confusion and have been so for many years. This confusion has been exacerbated by the recently promulgated temporary regulation adopted by the Internal Revenue Service under the revised installment sale provisions. This article critically analyzes that regulation and offers two modifications to the IRS’s approach that are necessary to inject clarity and fairness into the taxation of non-installment-sale transactions.

Keywords: Non-installment-sale Transactions, Internal Revenue Code section 453, Internal Revenue Service Regulations

Suggested Citation

Karjala, Dennis S., Sales of Property Outside Section 453 (1986). 64 Taxes 153 (1986). Available at SSRN:

Dennis S. Karjala (Contact Author)

Arizona State University College of Law ( email )

Box 877906
Tempe, AZ 85287-7906
United States
480-965-4010 (Phone)
480-965-2427 (Fax)


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