Prescott Real Estate Holdings, Inc. sells timeshares in Hawaii as it primary business (typically it sells 40-50 timeshares a year). Prescott has well over $5 million in installment obligations outstanding at December 31, 2016 as a result of its timeshare sales in Hawaii and other locations. In 2016, Stephen Colbert, an unrelated single taxpayer, purchases a four-week timeshare from Prescott and agrees to pay $15,000 down at the time of purchase (July 4, 2016) and $5,000 per year for the next two years starting December 2016 and then a $10,000 final payment on December 2018. Colbert also agrees to a 4.7% rate of interest on the installment obligation (market rate for this type of loan). Colbert is not a U.S. tax resident for Federal tax purposes. In 2020, Colbert sells the timeshare to his sister.Prescott wishes to defer the recognition of gain on this transaction for as long as possible.Your responsibilities:Prepare a tax research memorandum in good form that provides your conclusion on what method might be available to Prescott to defer recognition of the gain on the sale of the timeshare.You will need to support your conclusion using primary sources of tax law. Your textbook is NOT primary authority. You should refer to only statutory (i.e., legislative) sources of tax law to respond to this question. You may research ANY tax authority (primary or secondary) but your solution must be derived and supported using only primary authority in this case, statutory only.You must use proper citation form in your memo (see the inside front cover of your text). The form for this communication should be professional and in the form of a tax research memo.This memo should be whatever length you feel is appropriate to resolve the issues. We do NOT use a bibliography or list of references in a tax research memo. You will see that citations are within the text of the document.