REC Structure Advice

[VAL A.]

Will someone tell me how to structure note? I'm wrapping two underlying loans totaling 175K....my equity on top is 70K...the interest is 6.5%....I was initially going to carry 3 yrs now thought of 30 yrs for the income....but after coming on this forum this week thought I should rethink this.

The interest rate is locked in but I can change the term to 5. I was originally only going to carry for 2 1/2 yrs because I thought I could avoid capital gains tax if I was cashed out in under 3 since this was my residence.
I called IRS and find that this sale becomes an installment sale and I'm taxed from the beginning based on some formula. Got the gist of it but didn't understand totally.

What would you suggest to make the best saleable note AND what would the note then be discounted for? I'm looking for some actual figures here....thanks

I'm new to this forum and hope I gave all the info needed.