The author examines the law regarding tax treatment of promises to pay in the future and finds it in a state of confusion. After discussing the inequities arising from the differing treatment accorded cash and accrual basis taxpayers the author suggests a number of changes in the tax treatment of installment sales and annuities given in exchange for property. The author also makes suggestions for simplification of the concept of cash equivalence
Don W. Llewellyn,
Promises to Pay in the Future-A Modest Proposal for Reform,
31 U. Miami L. Rev.
Available at: http://repository.law.miami.edu/umlr/vol31/iss5/2