TP purchased unimproved real property in year 1 with a fair market value of $450,000 by paying cash of $200,000 and assuming a pre-existing liability of the seller to a bank (secured by a mortgage on the real property) in the principal amount of $250,000. On December 31, year 8, when TP’s basis in the property was $450,000 and its fair market value was $800,000, TP sold the property to Buyer according to the following terms: 1. Buyer paid TP $225,000 cash at the closing, 2. Buyer assumed the mortgage indebtedness on the property, the principal amount of which at the time of TP’s sale was $150,000, and 3. Buyer executed a promissory note payable to TP in the total principal amount of $425,000. A principal payment of $85,000 was due on the anniversary date of the sale in each of the five years following the year of sale. The promissory note required the payment of interest at 5% compounded annually, and the note had a fair market value of $425,000. TP received the required $85,000 payment of principal on the note in year 9, and on January 1, year 10, TP transferred the note (entitled to four additional principal payments of $85,000) to TP’s child as a gift. The fair market value of the note on January 1, year 10, was $340,000. Calculate TP's amount realized in year 8 due to the sale according to §453.
