MATTER OF McCONNELL v. STATE TAX COMM'N


87 A.D.2d 683 (1982)

In the Matter of Neil A. McConnell et al., Petitioners, v. State Tax Commission, Respondent

Appellate Division of the Supreme Court of the State of New York, Third Department.

March 4, 1982


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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