The dispositive issue in this proceeding is whether respondent correctly determined that petitioner's election to report a sale of stock on his 1972 State resident income tax return under the installment method was improper. Petitioner was the sole shareholder of Abbey Chop House, Inc., a corporation which operated a restaurant in a New York City hotel. Only 13 8/10 shares of stock had been issued by the corporation. On June 14, 1972, at...
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