At issue is the fair market value of petitioners' 49% interest in Funplex, Inc., a closely held corporation formed by petitioners and respondents to construct and operate a seasonal outdoor recreational facility in the Town of East Greenbush, Rensselaer County. The complex, which included a miniature golf course, batting cages and a "Bank Shot Basketball" game, opened in mid-August 1992, taking in approximately $103,000 in gross revenue...
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