Today we hear from Barry in WI who is doing research. He says, “I am searching for the IRS definition concerning related parties and installment notes between related parties and any new cases concerning this issue.”
IRS has several definitions for related parties – depending on the issue.
In the case of installment sales, which may be different from installment notes, the definition is easy to find. Read the instructions to Form 6252 – Installment Sale Income.
On page 2, it defines related parties as :
For this purpose, a related party includes your spouse, child, grandchild, parent, brother, sister, or a related corporation, S corporation, partnership, estate, or trust. See section 453(f)(1) for more details.
Now all you need to do is research case law related to IRC 453(f)(1) .
http://www.legalbitstream.com shows 44 cases with this code section.
You should be able to find what you need there.
And remember, you can find answers to all kinds of questions about installment sales and all kinds of other tax issues, free. Where? Where else? At TaxMama.com[Note: If you were subscribed to the e-mailed TaxQuips, you’d be getting other exciting news and tips by e-mail, that never appear on the site. Please click on the subscribe link and join us.]
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- IRS Form 6252 :: Installment Sale Income
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