The deceased taxpayers, George and Mildred Rapoport, were legal residents of the State of Florida during the taxable years in question. In 1969, they sold an apartment building consisting of 140 units located in Flushing, New York, and took back a purchase-money second mortgage for the unpaid balance of the purchase price. The mortgage note provided for interest at the rate of 6% per annum and quarterly payments of principal and interest commencing...
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