The instant appeals are closely interrelated and will be considered together. The pertinent facts are as follows: Petitioner Irving Mason and his now deceased wife Gussie Mason were the owners of 180 acres of land at Divine Corners, Sullivan County, New York, which they developed into a trailer park called Foxcroft Village, Inc. (hereinafter Foxcroft). They were also the sole shareholders and corporate officers of Foxcroft, and as fee owners, they leased their entire 180...
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