In 1989, petitioner Sash A. Spencer (hereinafter Spencer), a Florida resident, received a guaranteed payment of $1,349,832 for his interest in a New York partnership. Petitioners reported the payment as ordinary income on their 1989 Federal income tax return, but did not do so on their 1989 New York State "nonresident and part-year resident" income tax return. The State Department of Taxation and Finance determined that they should have and...
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