On April 16, 1975, petitioner James Paris formed the respondent corporation, Anthony Ave. Realty Corp., to own and manage a building located at 501 West 189th Street in Manhattan. In September of 1975, petitioner sold one half of his interest in the closely held corporation to Martha and Edmond Contouris, retaining half of the stock for himself. Subsequently, on July 28, 1976, petitioner agreed to sell the remaining shares of his stock to Mr. and Mrs. Contouris for $4,900...
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