On March 30, 1982, petitioners acquired two contiguous parcels of real property in Manhattan from a common grantor via separate deeds for each parcel. The purchase price was $125,000 per parcel, and separate purchase-money mortgages of $100,000 were held by the grantor. Although contiguous, the properties were physically separate and independent and could be freely transferred separately. Both parcels were used for commercial/residential rental...
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