This proceeding arises out of a transaction in which petitioner sold an office building to Aetna Life Insurance Company (Aetna) for a total purchase price of $59,093,527 pursuant to a contract of sale dated July 29, 1981. At the time the property was conveyed (Feb. 23, 1983), there were various construction loans outstanding in the aggregate amount of $50,000,000 which were secured by a series of five mortgages held by Manufacturers Hanover Trust Company (MHT). At the closing...
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