LYNN, J.
The respondent, New Hampshire Department of Revenue Administration (DRA), appeals a decision of the Superior Court (Vaughan, J.) ruling that distributions which The Lyme Timber Company (Lyme) made to the petitioners, certain of its limited partners who reside in New Hampshire, are not taxable income to the individual petitioners because their beneficial interests in Lyme are not "transferable shares" within the meaning of RSA chapter 77. See
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