WILKINS, J.
The taxpayers appeal from a determination of the Appellate Tax Board (board) that gain included within an instalment payment, received in 1971, on a 1965 sale of an interest in Florida real estate was income taxable under the Massachusetts income tax law. The taxpayers, who were residents of the Commonwealth at all material times, elected to report the sale by the instalment method for Federal income tax purposes. See Int. Rev. Code of 1954, § 453...
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