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The Installment Sale Report 2026
The Installment Sale Report is the annual reference for how often installment sales are reported to the IRS, how large they are, what the section 453A interest charge costs, and what interest rate a seller note needs. Every number is dated and linked to its IRS or statute source; the tables download as CSV under CC BY 4.0. Written for property and business sellers, listing brokers, CPAs and reporters.
The Installment Sale Report 2026 · Edition 1 · IRS data through tax year 2023 (Publication 4801, June 2026) · applicable federal rates through October 2026 · last updated · cite this report · data free to reuse under CC BY 4.0
Key findings, edition 1 (October 14, 2026)
- Installment sale forms outnumber like-kind exchange forms 8.4 to 1: 461,458 Form 6252 forms against 54,746 Form 8824 forms for tax year 2023, up from 1.9 to 1 in tax year 2017. (IRS SOI Pub. 4801, tax year 2023 and 2017; ratio calculated, retrieved October 14, 2026)
- Form 6252 filings fell 32.5% from 683,552 (tax year 2010) to 461,458 (tax year 2023), and have been flat since tax year 2019 (463,472). (IRS SOI line-item estimates, tax years 2010, 2019, 2023; change calculated, retrieved October 14, 2026)
- The average selling price on forms that report one rose 29%, from $810,053 (tax year 2019) to $1.04 million (tax year 2023), on 437,698 forms. (IRS SOI Pub. 4801, Form 6252 line 5, tax years 2019 and 2023; average calculated, retrieved October 14, 2026)
- The section 453A interest charge totaled $402.2 million on 6,492 individual returns for tax year 2023, up 162% in dollars from tax year 2021 on 26% fewer returns. (IRS SOI Pub. 4801, Schedule 2 line 15, tax years 2021 and 2023; change calculated, retrieved October 14, 2026)
- In a worked example, a $7,000,000 note outstanding at year end triggers about $21,000 of 453A interest for 2026; the same sale with a $5,000,000 note triggers $0, so the $5 million line is not a cliff. (26 U.S.C. 453A and IRS Pub. 537 (2025) formula, Rev. Rul. 2026-15 rate; illustration, not IRS data, retrieved October 14, 2026)
- The long-term applicable federal rate is 5.22% for October 2026, the highest of the 22 monthly rates from January 2025 to October 2026 (low: 4.53% in January 2025). (IRS Rev. Rul. 2026-19 and the 21 earlier monthly AFR rulings, Table 1, annual compounding, retrieved October 14, 2026)
Installment sale forms outnumber like-kind exchange forms 8.4 to 1
For tax year 2023 the IRS counted 461,458 Form 6252 installment sale income forms and 54,746 Form 8824 like-kind exchange forms with individual returns, a ratio of 8.4 to 1 (calculated). In tax year 2017 the ratio was 1.9 to 1. Source: IRS Statistics of Income, Publication 4801, tax years 2023 and 2017, Totals for Forms and Schedules, rows Form 6252 and Form 8824. Retrieved October 14, 2026.
| Tax year | Form 6252 (installment sale) | Form 8824 (like-kind exchange) | 6252 per 8824 (calculated) | IRS source |
|---|---|---|---|---|
| 2010 | 683,552 | 158,299 | 4.3 | table |
| 2011 | 661,292 | 170,268 | 3.9 | table |
| 2012 | 641,959 | 194,563 | 3.3 | table |
| 2013 | 609,520 | 235,374 | 2.6 | table |
| 2014 | 606,385 | 249,366 | 2.4 | table |
| 2015 | 546,523 | 264,532 | 2.1 | table |
| 2016 | 534,808 | 259,289 | 2.1 | table |
| 2017 | 496,698 | 263,470 | 1.9 | table |
| 2018 | 503,539 | 57,502 | 8.8 | table |
| 2019 | 463,472 | 56,674 | 8.2 | table |
| 2020 | 465,993 | 53,238 | 8.8 | table |
| 2021 | 461,165 | 89,215 | 5.2 | table |
| 2022 | 465,500 | 72,980 | 6.4 | table |
| 2023 | 461,458 | 54,746 | 8.4 | table |
Average selling price on installment sale forms rose 29% in four years, to $1.04 million
Among Form 6252 forms that reported a selling price, the average rose from $810,053 (tax year 2019) to $1,044,067 (tax year 2023), calculated from line 5 totals of $325.7 billion and $457.0 billion over 402,019 and 437,698 forms. Total selling price rose 40% over the same four years. Source: IRS Statistics of Income, Publication 4801, tax years 2019 to 2023, Form 6252 count and amounts pages, line 5. Retrieved October 14, 2026.
| Tax year | Forms reporting a price | Selling price (line 5) | Gross profit (line 16) | Installment sale income taxed that year (line 24) | Average price per form (calculated) | IRS source |
|---|---|---|---|---|---|---|
| 2019 | 402,019 | $325.7B | $240.0B | $46.0B | $810,053 | table |
| 2020 | 418,876 | $387.1B | $286.8B | $48.7B | $924,029 | table |
| 2021 | 428,553 | $425.4B | $318.0B | $70.6B | $992,741 | table |
| 2022 | 442,775 | $459.7B | $349.0B | $59.0B | $1,038,307 | table |
| 2023 | 437,698 | $457.0B | $345.3B | $48.4B | $1,044,067 | table |
The 453A interest charge totaled $402.2 million in 2023, up 162% from 2021 on 26% fewer returns
Individuals reported $402.2 million of interest on the deferred tax of installment sales over $150,000 on 6,492 returns for tax year 2023, an average of $61,960 per return (calculated). In tax year 2021 it was $153.4 million on 8,736 returns. Source: IRS Statistics of Income, Publication 4801, tax years 2021 to 2023, Schedule 2 (Form 1040), line 15, returns and amounts pages. Retrieved October 14, 2026.
| Tax year | Returns | Interest reported | Average per return (calculated) | IRS source |
|---|---|---|---|---|
| 2021 | 8,736 | $153.4M | $17,557 | table |
| 2022 | 9,783 | $316.7M | $32,373 | table |
| 2023 | 6,492 | $402.2M | $61,960 | table |
How the $5 million threshold works, with a worked example
Section 453A adds an interest charge on the tax a seller has not yet paid when an installment sale is over $150,000 and the notes from such sales that arose in the year and are still outstanding at year end exceed $5,000,000. IRS Publication 537 (2025) computes it as: deferred tax liability (unrecognized gain on the note times the maximum tax rate for the year), times an applicable percentage ((outstanding notes minus $5,000,000) divided by outstanding notes), times the IRS underpayment rate. The applicable percentage is set in the year of sale and does not change as payments are made. Sources: 26 U.S.C. 453A(b) and (c); IRS Publication 537 (2025), Interest on Deferred Tax; IRS Revenue Ruling 2026-15 (7% underpayment rate, fourth quarter 2026). Retrieved October 14, 2026.
| Step | Amount |
|---|---|
| Sales price (illustration) | $8,000,000 |
| Adjusted basis (illustration) | $2,000,000 |
| Gross profit percentage | 75% |
| Down payment received in 2026 (illustration) | $1,000,000 |
| Face amount of the note outstanding at year end | $7,000,000 |
| Unrecognized gain on the note ($7,000,000 x 75%) | $5,250,000 |
| Deferred tax liability (x 20% assumed maximum long-term capital gain rate) | $1,050,000 |
| Applicable percentage (($7,000,000 - $5,000,000) / $7,000,000) | 28.57% |
| Underpayment rate, fourth quarter 2026 | 7% |
| 453A interest charge ($1,050,000 x 28.57% x 7%) | $21,000 |
Result: about $21,000 of additional tax for 2026. The same sale with a $5,000,000 note outstanding produces an applicable percentage of zero and no charge. The charge scales with the part of the note above $5,000,000, so $7,000,000 is charged on 28.57% of the deferred tax, not all of it. Personal-use property sold by an individual and property used or produced in farming are outside section 453A (26 U.S.C. 453A(b)(3)). State tax, net investment income tax and your own facts change real results; this table is arithmetic on the IRS formula, not IRS data and not advice for a specific sale.
The long-term AFR is 5.22% for October 2026, the highest of the last 22 months
The IRS set the October 2026 applicable federal rates at 4.25% (short-term, notes up to 3 years), 4.61% (mid-term, over 3 up to 9 years) and 5.22% (long-term, over 9 years), annual compounding. January 2025 was 4.33%, 4.24% and 4.53%. Source: IRS Revenue Ruling 2026-19, Table 1, and the 21 earlier monthly Table 1 rulings listed below. Retrieved October 14, 2026.
| Month | Short-term | Mid-term | Long-term | IRS source |
|---|---|---|---|---|
| October 2026 | 4.25% | 4.61% | 5.22% | Rev. Rul. 2026-19 |
| September 2026 | 4.18% | 4.49% | 5.12% | Rev. Rul. 2026-17 |
| August 2026 | 4.10% | 4.35% | 4.92% | Rev. Rul. 2026-13 |
| July 2026 | 4.00% | 4.35% | 4.98% | Rev. Rul. 2026-12 |
| June 2026 | 3.85% | 4.13% | 4.87% | Rev. Rul. 2026-11 |
| May 2026 | 3.82% | 4.08% | 4.83% | Rev. Rul. 2026-9 |
| April 2026 | 3.59% | 3.82% | 4.62% | Rev. Rul. 2026-7 |
| March 2026 | 3.59% | 3.93% | 4.72% | Rev. Rul. 2026-6 |
| February 2026 | 3.56% | 3.86% | 4.70% | Rev. Rul. 2026-3 |
| January 2026 | 3.63% | 3.81% | 4.63% | Rev. Rul. 2026-2 |
| December 2025 | 3.66% | 3.79% | 4.55% | Rev. Rul. 2025-24 |
| November 2025 | 3.69% | 3.83% | 4.62% | Rev. Rul. 2025-21 |
| October 2025 | 3.81% | 3.87% | 4.73% | Rev. Rul. 2025-19 |
| September 2025 | 4.00% | 4.04% | 4.83% | Rev. Rul. 2025-17 |
| August 2025 | 4.03% | 4.06% | 4.82% | Rev. Rul. 2025-14 |
| July 2025 | 4.12% | 4.19% | 4.90% | Rev. Rul. 2025-13 |
| June 2025 | 4.00% | 4.07% | 4.77% | Rev. Rul. 2025-12 |
| May 2025 | 4.05% | 4.10% | 4.62% | Rev. Rul. 2025-10 |
| April 2025 | 4.16% | 4.21% | 4.61% | Rev. Rul. 2025-8 |
| March 2025 | 4.31% | 4.46% | 4.82% | Rev. Rul. 2025-6 |
| February 2025 | 4.34% | 4.52% | 4.86% | Rev. Rul. 2025-5 |
| January 2025 | 4.33% | 4.24% | 4.53% | Rev. Rul. 2025-1 |
“Most sellers have heard of the 1031 exchange. The IRS counts show the installment method is reported on about eight times as many forms. And the $5 million line in section 453A is not a cliff: the interest charge applies only to the share of the deferred tax above it.”
Methodology
- Source. Primary government documents only: IRS Statistics of Income individual line-item estimates (Publication 4801 and the earlier line-count editions on the IRS SOI page), IRS Publication 537 (2025), the monthly IRS Revenue Rulings, the Internal Revenue Code on GovInfo. No survey, no third-party estimate.
- What a number is. Form counts are IRS SOI estimates of forms filed with individual returns (a sample-based estimate, not a census), by tax year, taken from the Totals for Forms and Schedules table. Dollar lines are in thousands as published. Tax year 2024 data is not yet released; edition 2 will add it when the IRS publishes it.
- Calculated values (ratios, percent changes, averages, the worked example) are labeled “calculated” or “illustration” and use only the published inputs shown beside them. Percent changes use unrounded IRS figures.
- Not covered. Corporations, partnerships and trusts are not in these counts; SOI counts forms, not sales, and one sale can produce a Form 6252 in many years. Tax year 2016 comes from the IRS line-count PDF for that year; every year links to its own IRS document in the tables above and in the CSVs.
- Verification. Every figure was extracted from the IRS document text on October 14, 2026 and cross-checked against the adjacent edition where both editions publish the same year. The 54 reference statistics further down are re-verified on the first of each month.
- Author and independence. Prepared by Hans Goldstein, Enrolled Agent, admitted to practice before the Internal Revenue Service. Not affiliated with or endorsed by the IRS. Educational, not tax or legal advice.
Download the data, license and how to cite this report
- installment-sale-report-2026-453a-interest.csv
- installment-sale-report-2026-453a-worked-example.csv
- installment-sale-report-2026-afr-history.csv
- installment-sale-report-2026-form6252-dollars.csv
- installment-sale-report-2026-form6252-vs-form8824.csv
- installment-sale-report-2026.json (key findings, citation and file list)
- installment-sale-statistics-2026.csv (the 54 reference statistics)
How to cite this report
Goldstein, H. (2026). The Installment Sale Report 2026, Edition 1. The Waterfall Strategy (Hans Goldstein: Tax & Exit Planning). Updated October 14, 2026. https://thewaterfallstrategy.com/installment-sale-statistics/ (CC BY 4.0).Short credit line
Source: The Installment Sale Report 2026, Hans Goldstein, Enrolled Agent, thewaterfallstrategy.com/installment-sale-statistics/Link (HTML)
<a href="https://thewaterfallstrategy.com/installment-sale-statistics/">The Installment Sale Report 2026</a> by Hans Goldstein, Enrolled Agent (CC BY 4.0)Reference: 54 sourced statistics on installment sales, section 453A and AFR notes
Key takeaways
- IRS counted 461,458 Form 6252 installment sale forms filed for tax year 2023. (Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801), 2026) details
- Form 6252 selling prices totaled $457.0 billion for tax year 2023. (Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801), 2026) details
- Installment sale income reported for tax year 2023 was $48.4 billion. (Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801), 2026) details
- The average Form 6252 selling price was about $1.04 million per form in 2023. (Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801), 2026) details
- Section 453A applies only when the sales price exceeds $150,000. (U.S. Code (GovInfo), 26 U.S.C. 453A, Special rules for nondealers, 2025) details
- The 453A interest charge needs more than $5,000,000 of obligations outstanding at year end. (U.S. Code (GovInfo), 26 U.S.C. 453A, Special rules for nondealers, 2025) details
- The IRS underpayment rate is 7% for the fourth quarter of 2026. (Internal Revenue Service, Interest rates remain the same for the fourth quarter of 2026 (Revenue Ruling 2026-15), 2026) details
- Individuals reported $402.2 million of 453A deferred tax interest for tax year 2023. (Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801), 2026) details
- The long-term applicable federal rate is 5.22% for October 2026. (Internal Revenue Service, Revenue Ruling 2026-19 (applicable federal rates for October 2026), 2026) details
- The 9% interest cap applies to seller notes up to $7,462,600 in 2026. (Internal Revenue Service, Revenue Procedure 2025-32 (2026 inflation adjustments), 2025) details
- A related buyer's resale triggers gain only within 2 years of the first sale. (U.S. Code (GovInfo), 26 U.S.C. 453, Installment method, 2025) details
- Depreciation recapture under section 453(i) is taxed in the year of sale. (U.S. Code (GovInfo), 26 U.S.C. 453, Installment method, 2025) details
- JCT estimates installment deferral costs $35.9 billion over fiscal years 2025 to 2029. (Joint Committee on Taxation, Estimates of Federal Tax Expenditures for Fiscal Years 2025-2029 (JCX-45-25), 2025) details
How many installment sales are reported to the IRS each year?
IRS Statistics of Income counted 461,458 Form 6252 installment sale income forms filed with individual returns for tax year 2023. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Totals for Forms and Schedules, row Form 6252.
The IRS Statistics of Income program estimates how many Form 6252 installment sale forms individuals file. The counts below come from line item estimates for tax years 2020, 2021 and 2023.
- For tax year 2021, individual taxpayers filed 461,165 Form 6252 installment sale income forms, according to IRS line item estimates. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2021 (Publication 4801) (February 2024), Form 6252 returns table, Total Forms Filed.
- For tax year 2020, individual taxpayers filed 465,993 Form 6252 installment sale income forms, according to IRS line item estimates. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2020 (Publication 4801) (November 2022), Totals for Forms and Schedules, row Form 6252.
- Of the Form 6252 installment sale forms filed for tax year 2023, 442,682 were filed electronically. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Totals for Forms and Schedules, row Form 6252, Electronically Filed.
- About 95.9% of Form 6252 installment sale forms for tax year 2023 were filed electronically, calculated from IRS figures of 442,682 e-filed out of 461,458 total. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Totals for Forms and Schedules, row Form 6252.
How much do sellers report on installment sales?
For tax year 2023, the selling price on line 5 of Form 6252 installment sale forms totaled $457.0 billion, per IRS Statistics of Income. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Form 6252 amounts page, line 5 (dollars in thousands).
Form 6252 shows the selling price, gross profit and payments for each installment sale. Dollar amounts in the IRS tables are published in thousands and rounded here to billions or millions.
- For tax year 2021, the selling price on line 5 of Form 6252 installment sale forms totaled $425.4 billion, per IRS Statistics of Income. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2021 (Publication 4801) (February 2024), Form 6252 amounts page, line 5 (dollars in thousands).
- For tax year 2020, the selling price on line 5 of Form 6252 installment sale forms totaled $387.1 billion, per IRS Statistics of Income. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2020 (Publication 4801) (November 2022), Form 6252 amounts page, line 5 (dollars in thousands).
- Form 6252 forms that reported a selling price for tax year 2023 averaged about $1.04 million per form, calculated from IRS figures of $456,986,081 thousand over 437,698 forms. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Form 6252 count and amounts pages, line 5.
- Gross profit reported on line 16 of Form 6252 installment sale forms totaled $345.3 billion for tax year 2023. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Form 6252 amounts page, line 16 (dollars in thousands).
- Payments received during the year on installment sales, line 21 of Form 6252, totaled $88.7 billion for tax year 2023. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Form 6252 amounts page, line 21 (dollars in thousands).
- Installment sale income taxed in the year, line 24 of Form 6252, totaled $48.4 billion for tax year 2023. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Form 6252 amounts page, line 24 (dollars in thousands).
- The part of installment sale income treated as ordinary income under the recapture rules, line 25 of Form 6252, totaled $217.9 million for tax year 2023. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Form 6252 amounts page, line 25 (dollars in thousands).
- Excluded gain on main home sales reported on line 15 of Form 6252 totaled $695.7 million for tax year 2023. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Form 6252 amounts page, line 15 (dollars in thousands).
- Form 4797 filers reported $10.9 billion of section 1231 gain from installment sales for tax year 2023. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Form 4797 amounts page, Part I, line 4 (dollars in thousands).
- About 186,602 Form 4797 filers reported section 1231 gain from installment sales for tax year 2023. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Form 4797 returns page, Part I, line 4.
What is the section 453A interest charge and when does it apply?
The section 453A interest charge applies to an installment obligation only when the sales price of the property exceeds $150,000. Source: U.S. Code (GovInfo), 26 U.S.C. 453A, Special rules for nondealers (2025), 26 U.S.C. 453A(b)(1).
Section 453A charges interest on the deferred tax of large nondealer installment sales. The charge is computed using the IRS underpayment rate and reported as additional tax.
- The 453A charge applies for a year only if the face amount of qualifying obligations that arose and remain outstanding at year end exceeds $5,000,000. Source: U.S. Code (GovInfo), 26 U.S.C. 453A, Special rules for nondealers (2025), 26 U.S.C. 453A(b)(2)(B).
- The IRS underpayment rate for the calendar quarter beginning October 1, 2026, is 7%, the same rate as the third quarter. Source: Internal Revenue Service, Interest rates remain the same for the fourth quarter of 2026 (Revenue Ruling 2026-15) (August 2026), News release text, list of new rates.
- The IRS underpayment rate under section 6621(a)(2) is the federal short-term rate plus 3 percentage points, reset quarterly. Source: U.S. Code (GovInfo), 26 U.S.C. 6621, Determination of rate of interest (2025), 26 U.S.C. 6621(a)(2).
- In the IRS Publication 537 example of a $15 million installment sale, the 2022 section 453A additional tax is $109,620. Source: Internal Revenue Service, Publication 537 (2025), Installment Sales (2026), Interest on Deferred Tax, computation example.
- In the same IRS example, the 2023 section 453A additional tax is $93,960, using an 8% underpayment rate. Source: Internal Revenue Service, Publication 537 (2025), Installment Sales (2026), Interest on Deferred Tax, computation example.
- For tax year 2023, 6,492 individual returns reported interest on deferred tax from installment sales over $150,000 on Schedule 2, line 15. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Schedule 2 (Form 1040) returns page, line 15.
- Interest on deferred tax from installment sales over $150,000, Schedule 2 line 15, totaled $402.2 million for tax year 2023. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Schedule 2 (Form 1040) amounts page, line 15 (dollars in thousands).
- Under the section 453A(d) pledge rule, net proceeds of debt secured by a covered installment obligation are treated as a payment received on that obligation. Source: U.S. Code (GovInfo), 26 U.S.C. 453A, Special rules for nondealers (2025), 26 U.S.C. 453A(d)(1).
- Section 453A(b)(3) exempts obligations from sales of personal use property by an individual and from property used or produced in farming. Source: U.S. Code (GovInfo), 26 U.S.C. 453A, Special rules for nondealers (2025), 26 U.S.C. 453A(b)(3).
What interest rate must a seller-carried note carry?
The short-term applicable federal rate for October 2026, for notes of three years or less, is 4.25% with annual compounding. Source: Internal Revenue Service, Revenue Ruling 2026-19 (applicable federal rates for October 2026) (September 2026), Table 1, Short-term AFR, annual.
A seller note needs adequate stated interest, generally measured against the applicable federal rate in sections 1274 and 483. Otherwise the IRS treats part of the price as interest.
- The mid-term applicable federal rate for October 2026, for notes over three and up to nine years, is 4.61% with annual compounding. Source: Internal Revenue Service, Revenue Ruling 2026-19 (applicable federal rates for October 2026) (September 2026), Table 1, Mid-term AFR, annual.
- The long-term applicable federal rate for October 2026, for notes over nine years, is 5.22% with annual compounding. Source: Internal Revenue Service, Revenue Ruling 2026-19 (applicable federal rates for October 2026) (September 2026), Table 1, Long-term AFR, annual.
- The mid-term federal rate applies to a seller note with a term over 3 years but not over 9 years, and the long-term rate applies beyond 9 years. Source: U.S. Code (GovInfo), 26 U.S.C. 1274, Determination of issue price in the case of certain debt instruments issued for property (2025), 26 U.S.C. 1274(d)(1)(A).
- A seller can use the lowest applicable federal rate in the 3-month window ending with the month a binding written contract for the sale is made. Source: U.S. Code (GovInfo), 26 U.S.C. 1274, Determination of issue price in the case of certain debt instruments issued for property (2025), 26 U.S.C. 1274(d)(2).
- For qualified debt instruments, the discount rate used for imputed interest under sections 483 and 1274 cannot exceed 9%, compounded semiannually. Source: U.S. Code (GovInfo), 26 U.S.C. 1274A, Special rules for certain transactions where stated principal amount does not exceed $2,800,000 (2025), 26 U.S.C. 1274A(a).
- For 2026, a qualified debt instrument under section 1274A(b) has stated principal that does not exceed $7,462,600, which is the limit for the 9% cap. Source: Internal Revenue Service, Revenue Procedure 2025-32 (2026 inflation adjustments) (October 9, 2025), Section 4.40.
- For 2026, a cash method debt instrument under section 1274A(c)(2) has stated principal that does not exceed $5,330,500. Source: Internal Revenue Service, Revenue Procedure 2025-32 (2026 inflation adjustments) (October 9, 2025), Section 4.40.
- For land sold between family members, the imputed interest discount rate cannot exceed 6%, compounded semiannually, on sales up to $500,000 per calendar year between the same individuals. Source: U.S. Code (GovInfo), 26 U.S.C. 483, Interest on certain deferred payments (2025), 26 U.S.C. 483(e).
- Section 1274 imputed interest does not apply when total payments and other consideration for the sale do not exceed $250,000. Source: U.S. Code (GovInfo), 26 U.S.C. 1274, Determination of issue price in the case of certain debt instruments issued for property (2025), 26 U.S.C. 1274(c)(3)(C).
Which gains cannot be deferred with an installment sale?
Dealer dispositions and sales of personal property that must be included in inventory are excluded from installment sale treatment under section 453(b)(2). Source: U.S. Code (GovInfo), 26 U.S.C. 453, Installment method (2025), 26 U.S.C. 453(b)(2).
Several categories of gain are recognized in the year of sale or are excluded from the installment method. Sellers can also elect out by the return due date.
- Under section 453(i), recapture income under sections 1245 or 1250 is recognized in the year of sale, and only gain above it uses the installment method. Source: U.S. Code (GovInfo), 26 U.S.C. 453, Installment method (2025), 26 U.S.C. 453(i).
- Under section 453(k), gain on stock or securities traded on an established securities market cannot be deferred, and all payments are treated as received in the year of sale. Source: U.S. Code (GovInfo), 26 U.S.C. 453, Installment method (2025), 26 U.S.C. 453(k)(2)(A).
- Under section 453(f)(4), a buyer note that is payable on demand or readily tradable is treated as receipt of payment, not as a deferred obligation. Source: U.S. Code (GovInfo), 26 U.S.C. 453, Installment method (2025), 26 U.S.C. 453(f)(4).
- Under section 453(d), a seller may elect out of the installment method only on or before the due date, including extensions, of the return for the year of the sale. Source: U.S. Code (GovInfo), 26 U.S.C. 453, Installment method (2025), 26 U.S.C. 453(d)(2).
- Section 453(l)(2)(A) keeps farm property sold on the installment plan out of the dealer disposition rule, so farm dealers can still use the installment method. Source: U.S. Code (GovInfo), 26 U.S.C. 453, Installment method (2025), 26 U.S.C. 453(l)(2)(A).
How do the related-party rules limit installment sales?
A resale by a related buyer can accelerate the seller's gain only if it happens not more than 2 years after the first sale, except for marketable securities. Source: U.S. Code (GovInfo), 26 U.S.C. 453, Installment method (2025), 26 U.S.C. 453(e)(2)(A).
Sales to relatives and controlled entities draw extra rules, including a resale rule and special treatment of depreciable property under sections 453(e), 453(g) and 1239.
- Under section 453(g), an installment sale of depreciable property between related persons gets no deferral: all payments are treated as received in the year of the sale. Source: U.S. Code (GovInfo), 26 U.S.C. 453, Installment method (2025), 26 U.S.C. 453(g)(1).
- Gain on depreciable property sold to a corporation or partnership more than 50 percent owned by the seller is ordinary income under section 1239. Source: U.S. Code (GovInfo), 26 U.S.C. 1239, Gain from sale of depreciable property between certain related taxpayers (2025), 26 U.S.C. 1239(c)(1).
How common are installment sales, and what federal data exists?
The IRS counted 461,458 Form 6252 installment sale forms filed with individual returns for tax year 2023, the closest official measure of how common installment sales are. Source: Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801) (June 2026), Totals for Forms and Schedules, row Form 6252.
No federal agency publishes a national share of sales that are carried by the seller. The figures below cover federal farm land contract support and the farmland market.
- The average U.S. farm real estate value was $4,500 per acre in 2026, up 3.4 percent from 2025, according to USDA NASS. Source: USDA National Agricultural Statistics Service, Land Values 2026 Summary (July 31, 2026), Agricultural Land Values Highlights.
- The average U.S. cropland value was $6,020 per acre in 2026, according to USDA NASS. Source: USDA National Agricultural Statistics Service, Land Values 2026 Summary (July 31, 2026), Agricultural Land Values Highlights.
- USDA ERS forecasts U.S. farm real estate debt will reach $399.0 billion in 2026. Source: USDA Economic Research Service, Farm Sector Income & Finances: Assets, Debt, and Wealth (September 3, 2026), Assets, Debt, and Wealth, debt forecast text.
- Under 2025 law, tax on gain from selling qualified farmland to a qualified farmer may be paid in four equal annual installments, according to JCT. Source: Joint Committee on Taxation, Estimates of Federal Tax Expenditures for Fiscal Years 2025-2029 (JCX-45-25) (December 3, 2025), Description of recent law changes affecting tax expenditures.
What does the installment method cost the Treasury?
Treasury estimates deferral of income from installment sales will reduce federal revenue by $27,460 million over fiscal years 2026 to 2035. Source: U.S. Department of the Treasury, Office of Tax Analysis, Tax Expenditures, Fiscal Year 2027 (December 16, 2025), Table 1, row 63, 2026-2035 column.
Treasury and the Joint Committee on Taxation each publish estimates of revenue lost to the deferral of gain on installment sales. Their methods differ, so the totals are not directly comparable.
- Treasury projects the revenue cost of deferral of income from installment sales will reach $3,310 million in fiscal year 2035. Source: U.S. Department of the Treasury, Office of Tax Analysis, Tax Expenditures, Fiscal Year 2027 (December 16, 2025), Table 1, row 63, 2035 column.
- The Joint Committee on Taxation estimates deferral of gain on non-dealer installment sales will cost $35.9 billion in revenue over fiscal years 2025 to 2029. Source: Joint Committee on Taxation, Estimates of Federal Tax Expenditures for Fiscal Years 2025-2029 (JCX-45-25) (December 3, 2025), Table 1, Deferral of gain on non-dealer installment sales, 2025-29 total.
Installment sale amounts reported on Form 6252 and Form 4797 ($ billions)
How to cite the 54 reference statistics
Suggested citation
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<a href="https://thewaterfallstrategy.com/installment-sale-statistics/">The Installment Sale Report 2026, reference statistics</a> (The Waterfall Strategy (Hans Goldstein: Tax & Exit Planning))Every statistic has its own anchor: link to #stat-id for one number. Download all 54 statistics (CSV)
Sources
- Internal Revenue Service, Interest rates remain the same for the fourth quarter of 2026 (Revenue Ruling 2026-15), August 2026.
- Internal Revenue Service, Publication 537 (2025), Installment Sales, 2026.
- Internal Revenue Service, Revenue Procedure 2025-32 (2026 inflation adjustments), October 9, 2025.
- Internal Revenue Service, Revenue Ruling 2026-19 (applicable federal rates for October 2026), September 2026.
- Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2020 (Publication 4801), November 2022.
- Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2021 (Publication 4801), February 2024.
- Internal Revenue Service, Statistics of Income, Individual Income Tax Returns Line Item Estimates, 2023 (Publication 4801), June 2026.
- Joint Committee on Taxation, Estimates of Federal Tax Expenditures for Fiscal Years 2025-2029 (JCX-45-25), December 3, 2025.
- U.S. Code (GovInfo), 26 U.S.C. 1239, Gain from sale of depreciable property between certain related taxpayers, 2025.
- U.S. Code (GovInfo), 26 U.S.C. 1274, Determination of issue price in the case of certain debt instruments issued for property, 2025.
- U.S. Code (GovInfo), 26 U.S.C. 1274A, Special rules for certain transactions where stated principal amount does not exceed $2,800,000, 2025.
- U.S. Code (GovInfo), 26 U.S.C. 453, Installment method, 2025.
- U.S. Code (GovInfo), 26 U.S.C. 453A, Special rules for nondealers, 2025.
- U.S. Code (GovInfo), 26 U.S.C. 483, Interest on certain deferred payments, 2025.
- U.S. Code (GovInfo), 26 U.S.C. 6621, Determination of rate of interest, 2025.
- U.S. Department of the Treasury, Office of Tax Analysis, Tax Expenditures, Fiscal Year 2027, December 16, 2025.
- USDA Economic Research Service, Farm Sector Income & Finances: Assets, Debt, and Wealth, September 3, 2026.
- USDA National Agricultural Statistics Service, Land Values 2026 Summary, July 31, 2026.
Educational only, not tax, legal or investment advice. Examples are illustrative. Have your CPA or tax attorney review your facts before you act. Hans Goldstein is an Enrolled Agent, admitted to practice before the Internal Revenue Service, and a licensed insurance agent (CA Insurance License #4273294). He is not a CPA or attorney. He is paid a commission only if a structured installment sale is funded; a plain installment note between buyer and seller pays him nothing. Disclosures.