Pursuant to a contract of sale entered into on December 31, 1985, petitioner agreed to sell to Keren Limited Partnership certain real property in Westchester County for $170,000,000. The purchase price was paid by two promissory notes, each secured by a purchase-money mortgage: the first for $102,000,000, due and payable on December 31, 1986 with interest at the rate of 11.25%; the second for $70,000,000, due and payable on December 31, 1988...
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