BobKamman
Level 15

Again, from Pub 537

Sale of Depreciable Property
If you sell depreciable property to certain related persons, you generally can’t report the sale using the installment method. Instead, all payments to be received are considered received in the year of sale. However, see Exception below. Depreciable property for this rule is any property the purchaser can depreciate.
Payments to be received include the total of all noncontingent payments and the FMV of any payments contingent as to amount.
In the case of contingent payments for which the FMV can’t be reasonably determined, your basis in the property is recovered proportionately. The purchaser can’t increase the basis of the property acquired in the sale before the seller includes a like amount in income.
Exception. You can use the installment method to report a sale of depreciable property to a related person if no significant tax deferral benefit will be derived from the sale. You must show to the satisfaction of the IRS that avoidance of federal income tax wasn’t one of the principal purposes of the sale.

Filed under "Taxpayers shooting themselves in foot"