Receipt of Payment in Installment Sales Transactions: Wraparound Mortgages and Letters of Credit

This Comment outlines the probable present status of the wraparound mortgage and the letter of credit after the Installment Sales Revision Act of 1980. It also examines temporary regulations promulgated pursuant to the Act which address, to some extent, both types of transactions. This Comment discusses whether these two security devices can be used without serious risk of being treated as payments received in the year of sale. To the extent that the security is treated as a payment rather than as security, the taxpayer will be forced to recognize income before actually receiving the proceeds from the sale of the property