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Ok, thanks, makes sense.  Let me probe the concept a bit further.  If 9 of the 10 cash installments were made prior to October occupancy, and only the final made in November, could the 9 installments be considered LT gain and only the portion of profit associated with the 10th installment be regular income?  Obviously a home is different than a stock, but similar situation with stock would be LT gain for those purchases that were over 1 year, and ST gain for those less than 1 year.  Thanks.