In November 1989, petitioner contracted to sell certain real property located in the Town of Southold, Suffolk County, for the sum of $3,304,544.50. Pursuant to this agreement, petitioner was to receive payment from the purchaser by, inter alia, a 10-year note in the amount of $1,252,694.50 secured by a purchase money subordinate mortgage. After deducting brokerage fees and claimed allowable selling expenses, petitioner reported to the...
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