LYNCH, J.
The question presented by this appeal is whether a nonresident who elects for Federal and State income tax purposes to pay tax on an instalment basis on a gain from the sale of Massachusetts real estate, see Int. Rev. Code of 1954, § 453(b), and G.L.c. 62, § 63, is subject to Massachusetts income tax under G.L.c. 62, § 63, on the interest earned on the instalment obligation note. The taxpayer appealed to the Appellate Tax Board (board) from...
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