John owns real estate with a fair market value of $1 million in which he has a basis of $250,000. In 2005, John sold the property to his son, Junior, for $1 million, subject to an installment note. Junior must pay the $1 million plus interest over 5 years. The note provides “Unless sooner discharged, upon John’s death, all amounts due under this note shall be deemed to be extinguished and treated as paid.”
Which of the following is true?
a. If John dies prior to receiving all payments, the present value of the installment payments not made will be included in Joe’s gross estate.
b. The unpaid installment payments are IRD.
c. No premium will be attached to the note since this is not a SCIN.
d. If John dies before he has paid off the note, he will not have to make any further payments.