Updated July 28, 2026. Quick answer: IRC §453(i)(1)(A) provides that “any recapture income shall be recognized in the year of the disposition” — and §453(i)(2) computes it as if all payments to be received were received in the taxable year of disposition. So a seller-financed deal with little or no money down can still produce a cash tax bill in year one.
The mechanic, and why it is worse than it sounds
Recapture is not spread. It is measured on the full price as though you had been paid in full, and taxed immediately. Only the gain above recapture goes onto the installment method under §453(i)(1)(B).
| Component of gain | When taxed | Character |
|---|---|---|
| Recapture under §1245/§1250 | Year one, in full | Ordinary |
| Everything above it | As payments are received | Generally capital |
The failure case is specific and avoidable. A business with heavily depreciated equipment, sold on a long note with a small down payment, can generate a year-one recapture bill larger than the cash received at closing. **Run the recapture number before agreeing to the payment schedule**, not after — the down payment is the variable that fixes it, and it is negotiable right up until it is not.
What decides how much recapture there is
The allocation. Consideration assigned to depreciable equipment carries recapture; consideration assigned to goodwill does not. Which is exactly why the allocation is negotiated rather than computed, and why the buyer’s preferred allocation is rarely yours.
Sources
IRC §453(a), (c), (d), (i); §453A(b), (c) and (d); Temp. Reg. §15a.453-1(c) and (d); §1060(a) and Treas. Reg. §1.1060-1(c) and (e); the asset classes at Treas. Reg. §1.338-6(b) as reproduced in the Instructions for Form 8594; §1042(a), (b), (c); §1202(a)(1) and (c)(1); §6621(a)(2). All read July 2026.
This states what the cited authority says. It is not tax advice, and retirement-plan design turns on facts about your business and your other entities that no page can see. Every dollar limit referenced here is indexed and changes annually.