Legal Opinion
Gurney v. Tully
Appellate Division of the Supreme Court of the State of New York
Decided April 19, 1979PublishedCited by 4 opinions
1Opinion of the Court
OPINION OF THE COURT
Mahoney, P. J.
The facts are not in dispute. In 1955 the petitioners, while residents of the State of North Carolina, entered into an agreement in which they sold the stock in certain closely held corporations with the proceeds to be paid to them on an installment basis. The installment payments began in 1955 and terminated in 1962. Petitioners subsequently became residents of New York. In an opinion letter, dated January 22, 1957, respondents notified petitioners that the deferred profit from this installment sale would not be taxable for purposes of New York income tax.…
2Cited by4 opinions
- Royal Indemnity Co. v. Tax Appeals TribunalNew York Court of Appeals · 1989
- MATTER OF GURNEY v. TullyNew York Court of Appeals · 1980
- Scholastic Bus Service, Inc. v. State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1986
- Royal Indemnity Co. v. Tax Appeals TribunalAppellate Division of the Supreme Court of the State of New York · 1989