O'CONNOR, J.
William I. Koch (taxpayer), a Massachusetts resident, reported on his Federal income tax return for 1983 a net long-term capital gain of $275,349,470 from 25 Subchapter S corporations which were incorporated in Delaware and did no business in Massachusetts. Internal Revenue Code § 1366, 26 U.S.C. § 1366 (1993), which in substance was also the provision in effect in 1983, allows gains or losses
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