Where a contract1 is entered into under which a chargeable interest2 is to be conveyed3 by one party to the contract ('A') at the direction or request of the other ('B'), to a person ('C') who is not a party to the contract, or either to such a person or to B, then B is not regarded as entering into a land transaction by reason of entering into the contract4. Instead:
(1) if the contract is substantially performed, B is treated5 as acquiring a chargeable interest, and accordingly as entering into a land transaction, and the effective date of
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