20 NYCRR 132.5(b) (b) Generally, where a nonresident individual sells real or tangible personal property located in New York State and, as a result of such sale receives intangible personal property (e.g., a note) which generates interest income, such interest income is not attributable to the sale of the real or tangible personal property but is attributable to the intangible personal property. Therefore, such interest income to a nonresident does not constitute income derived from or connected with New York State sources. However, where the instrument used to generate interest income as a result of a sale of real or tangible personal property located in New York State is employed in a business, trade, profession or occupation carried on in New York State, such interest income does constitute income derived from or connected with New York State sources.