University of Miami Law Review


When a taxpayer sells property and receives a purchaser's obligation in exchange, the Internal Revenue Service's new reporting rules for cash and accrual basis taxpayers result in inconsistent applications of section 1001(b) of the Internal Revenue Code. In Revenue Ruling 79-292, the Service treats section 1001(b) as being modified by section 451's method of accounting rules, this position subsequently has been incorporated into the temporary regulations under the Installment Sales Revision Act of 1980. The author argues that section 1001(b) operates independently of a taxpayer's method of accounting and that the Service's position creates doctrinal disharmony in the area of deferred reporting.