Many practitioners believe that using a note would constitute economic payment and not cause disqualification if the note is negotiable, bears interest at a market rate, is
payable on demand and is secured by the GRAT's assets.
If a seller receives evidence of indebtedness that is payable on demand or readily tradable, the debt instrument is treated as payment (Section 453(f)(4)).
The Seventh Circuit Court of Appeals believed the term payable on demand refers to cases in which the amount is already set and the seller has the right to choose the time of payment.