G.D. Parker, Inc., T.C. Memo. 2012-327

(petitioner sold partnership interest on installment basis; under installment contract, petitioner entitled to receive $7 million in 2004, but actually received $1 million of it in 2003 and $6 million in 2004; petitioner reported no gain in 2003 attributable to contract on basis that $1 million constituted loan; court determined that no evidence of loan present and $1 million was part of installment sale with result that capital gain produced in 2003 under contract).