Where a contract1 for a land transaction2 is entered into under which the contract is to be completed by a conveyance3, a person is not regarded as entering into a land transaction by reason of entering into the contract4, but:
(1) if the transaction is completed without previously having been substantially performed5, the contract and the transaction effected on completion are treated as part of a single land transaction, and the effective date of the transaction in this case is the date of completion
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