1.    453B: if you dispose of your note early, the G is going to tax you on the note in line with the acceleration of your receipt
2.    upon the disposition of an installment obligation, gain or loss is recognized to the extent of the difference b/w the B in the obligation and either:
1.    the amount realized in the case of satisfaction at other than face value or a sale or exchange, or
2.    the FMV of the obligation at the time of any other distribution, transmission, or disposition
b.    Under 453B, a taxpayer’s B in an installment note is the face value of the note minus the amount that would be taxable if the note was satisfied in full.
i.    See page 376 for an example
3.    United Surgical Steel Co. v Commissioner (1970)
a.    did petitioner “dispose of” installment obligations during its taxable year?
1.    the respondent “pledged” his installment sale as collateral as a loan, and states in opposition to the G assertation that a “pledge” does not fall into 453B’s “otherwise disposed of” category—the court says that this is a loan in form as well as substance and is not a sale of the collateral and, t/f is not governed by the provisions in 453B
ii.    the court says that this is a loan, however, Ascher says that it is closer than that;
iii.    Congress comes back and gets §453A to get you when certain transactions are of a certain size