Proposed regulations will provide generally that a taxpayer does not recognize gain or loss under section 453B of the Internal Revenue Code on certain dispositions of an installment obligation if gain or loss is not recognized on the disposition under another provision of the Code. The proposed regulations also will clarify that a taxpayer must recognize gain or loss under section 453B on the satisfaction of an installment obligation when the taxpayer transfers an installment obligation: (1) to the corporation that issued the obligation in exchange for stock in the corporation; or (2) to the partnership that issued the obligation in exchange for an interest in the partnership.