On or about April 1, 1968, petitioner was formed by the execution of a written joint venture agreement. Each of the 29 members contributed so that a total sum of $850,000 was raised and immediately loaned to the 59th and Madison Realty Corp. in exchange for a note and mortgage in that sum so that the latter might purchase the sublease of premises located at 635 Madison Avenue, said lease expiring in 2053. The property consisted of a 19-story building occupied by many commercial...
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