Taxation
IRS Issues Proposed Regulations on Application of Section 704(c) to Installment Obligations and Contributed Contracts
Monte A. Jackel and Glenn E. Mincey
On November 24, 2003, the Service and the Treasury Department (“Treasury”) promulgated proposed regulations relating to the treatment under sections 704(c) and 737 of installment obligations and property acquired pursuant to a contract. REG–160330–02, 68 Fed. Reg. 65,864 (Nov. 24, 2003). ...