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  1. S corporation treatment is discussed in Part II of this article.(8) The fact that the shareholder is treated as receiving the installment note for stock bars use of Sec. 453(h)(2) provides that a shareholder who receives liquidating distributions in more than one tax year must, on the liquidation's end, reallocate stock basis among all properties received; this requires (when necessary) amended returns for all appropriate tax years. See TD 8762 (1/27/98).(14) Generally, a taxpayer receiving payments under a contingent-price installment note recovers basis in accordance with the maximum amount receivable (if applicable). Such gain or loss is deemed to result from the sale or exchange of the property for which the note was received; see Sec.