Very difficult to determine pricing without seeing it. 

If the lease allows a new owner to terminate the lease with 90 days notice, it has to be determined what is the easier/cheaper option.  

One document we used was an appeal letter to the IRS saying that all proceeds from the sale would go towards the lien.

You CPA will have to determine the taxable implications from the “note” verses a “cash” pay off until the note is paid off. 

In both cases, syndication would be needed with a securities attorney.Here is the list of promissory notes recognized by the Supreme Court as NOT being securities is a compilation of nearly random examples:Notes delivered in consumer financing.Notes secured by a mortgage on a home.Short-term notes secured by a lien on a small business or some of its assets.Notes evidencing a “character” loan to a bank customer.Short-term notes secured by an assignment of accounts receivable.Notes that formalize an open-account indebtedness incurred in the ordinary course of business.Notes given in connection with loans by a commercial bank to a business for current operations.And the determining factors for how a court will judge it to be a security or not are :Whether the borrower’s motivation is to raise money for general business use, and whether the lender’s motivation is to make a profit, including interest.Whether the borrower’s plan of distribution of the note(s) resembles the plan of distribution of a security.Whether the investing public reasonably expects that the note is a security.Whether there is a regulatory scheme that protects the investor other than the securities laws (e.g., notes subject to certain banking regulations).Again, consult an attorney.

exactly, concluded accounts can lead to a mess with tax and a nightmare with the IRS

You need to see what other similar properties are selling for and that will pretty much determine your numbers.

The administration announced doubling the size of the IRS over ten years.

I have read online that the IRS would recommend I hold the investment property for at least 2 years but it's not a strict requirement.

How did you determine your rent income/occupancy rate?