Your client Bob Young is negotiating a sale of investment real estate for $12 million. Bob believes that the buyer would pay cash of $8 million and a note for $4 million. Or $3 million cash and a note for $9 million. The note will pay interest slightly above the market rate. Bob realizes that the second option involves more risks of collection, but he is willing to accept that risk if the tax benefits of the installment sale are substantial. What are the tax consequences of choosing the lower down payment and larger note option, assuming he has no other installment receivables?