Petitioners owned the "Buffalo Hockey Club", which they operated as a partnership for 14 years. In 1970, they sold all of their right, title and interest in and to the business for $1,200,000, receiving $300,000 in cash and the balance in a series of promissory notes aggregating $900,000, bearing interest at 4% per annum. Respondent, relying solely upon Tax Law § 705 (a), determined that the interest...
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