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This is a tax advantaged transaction in the oil or gas industry. A three-party arrangement in financing the purchase of a mineral lease. There are three parties to this transaction. A is the owner seller of the gas or oil well. B is the operator buyer. C is a corporation. A sells her working interest to the operator B for cash and the right to a larger payment when the well produces. A then sells the right to the production payment to C which pays A in cash borrowed on C’s pledge of the production payment. A gets cash taxed at capital-gains rates. B is happy because he just paid part of the purchase price with nontaxable production income.

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