OPINION OF THE COURT
MICHAEL C. LYNCH, J.
Plaintiffs, residents of Tennessee, were shareholders of JBS Sports, Inc., incorporated in Tennessee and taxable as an S corporation for federal and New York State income tax purposes. In 2007, plaintiffs sold all their stock to a third party, Yahoo, Inc. As part of this sale, JBS and Yahoo made an election under Internal Revenue Code (26 USC) § 338 (h) (10...
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