Petitioner, a partner in the New York City law firm of Shearman & Sterling since 1948, retired as of December 31, 1977 and moved to Florida, where he has been a resident since January 1, 1978. Upon his retirement, the law firm paid petitioner in full for his share of the firm's capital. Thereafter, he received annual retirement benefits from the firm pursuant to a formula set forth in the partnership agreement. On his 1981 New York nonresident...
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