This comment will consider the extent to which a taxpayer must, because he received written evidence of the buyer's obligation to pay money in the future, recognize income at the time of the sale. The obligation received could be a simple promissory note, negotiable paper, a note secured by a mortgage, or as in Heller an installment contract. Although the availability of installment sales reporting under section 453 is an important consideration in the area, the comment will not deal with that aspect of the problem. A brief history of the pertinent statutory language and a consideration of what this language has come to mean to both accrual and cash basis taxpayers will be considered in the remainder of the article.

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