¶ Petitioners, Andrew and Milton Rosenberg, are partners in the business of A & M Rosenberg, engaged in the rental of industrial property. In 1963, the firm became involved in the leasing of portable classrooms to various school districts. Two classrooms were rented in 1964 and an additional 15 were rented the following year. In partnership tax returns for 1964 and 1965, petitioners paid no unincorporated business income tax, and claimed an exemption pursuant to...
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