Unique deal structure - advice wanted

[Jim Myers]

I own and operate 7 MHP communities in Florida. I have a elderly MultiFamily property seller that wants to avoid capital gains taxes in his lifetime by implementing this unique deal structure which my CPA said would work. I want to know if anybody has heard or completed a similar deal or can offer advice. In this special circumstance the seller does not want or need a lump sum of cash from the sale, The seller would be happy with a monthly bonus from the operation and leave the remainder of the asset sale to his heirs.

$5,000,000 MHP community (current value) @10CAP

Conventional financing of $5MM, 30% down ($1.5M down) , 20yr term 6.75% = $26600/mo pmt or $312,000/yr P&I. ...This would result in seller having a capital gain tax burden. 

Seller suggests:

Option1
 Master Lease the community for 120 months @$25,0000/mo and option to purchase for $2,300,000 in 2033 (equilavent to mortgage balance in 10yr). In 2033 seller will be dead, His heirs will get a STEPUP BASIS in the property and avoid capital gains, the seller will get a monthly benefit without the hassle's of operating the community while he is alive.

In this option I did NOT pay the 30% down payment , but I could provide a 1st position cash out refi too the seller for $1M - $1.5M 

I would need to make sure the seller did not encumber the property during my master lease with a mortgage, i would lose any ability to do a cash out refi for 10yrs and I would lose the ability to capitalize expenses, and have depreciation, The seller would need to make sure that I did not operate the community where code liens or tax liens encumbered the property.

Has anybody heard of such a deal strategy? Any recommendations?