Petitioner transferred his 50% leasehold interest as a tenant in common of real property located at 77 Water Street to 77 Water Street Associates, a newly formed partnership, in exchange for a 50% interest in the partnership. The balance was held by 77 Water Street Inc., which purchased the other 50% leasehold interest in the property held by Louis Feil as tenant in common to avoid a liquidation of his interest in the property. At the closing, Feil was credited with $27,400...
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