Petitioners, as husband and wife, filed joint New York State income tax returns for the years 1971 and 1973. In 1971 they borrowed money for which they signed a promissory note, and in that year they paid interest on the note in the amount of $477,291.71. The borrowed money was used to purchase a $10,000,000 8% convertible corporate note, which produced interest income to petitioners in the amount of $600,000 in 1971. Additionally in that year, petitioners made interest payments...
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