Katz v. State Tax Commission

— Yesawich, Jr., J.

Prior to January of 1972, William Katz, a New York resident, and Hyman Gilinsky were partners. The sole asset of their partnership was a parcel of real property located in the City of *1030Binghamton and leased to an automobile dealership. Katz’s spouse, in partnership with Yetta and Stanley Gilinsky, owned a separate parcel of property, also located in Binghamton and leased to another automobile dealership. Late in 1971, the Katzs, petitioners herein, sold their respective interests in the properties to the remaining partners, in exchange for which petitioners received payment…