About This Blog
Taxes in New York (TiNY) is a blog by the Hodgson Russ LLP State and Local Tax Practice Group members Chris Doyle, Peter Calleri, and Zoe Peppas. The weekly reports are intended to go out every Tuesday after the New York State Division of Tax Appeals (DTA) publishes new ALJ Determinations and Tribunal Decisions. In addition to the weekly reports, TiNY may provide analysis of and commentary on other developments in the world of New York tax law.
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LinkedIn ProfileTiNY Report for June 20, 2019 (reporting on DTA cases published June 13 and 20)
This week we have a Decision and two Determinations. And yes, you read that date right, we have a same day determination – now that’s exciting stuff folks!
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TiNY Report for June 13, 2019 (reporting on DTA cases published May 30 and June 6)
A Decision, a Determination, and an Order this week (which was missed last week). We never said we were perfect, but we will try to not make this a habit.
TiNY Report for June 7, 2019 (reporting on DTA cases issued May 29 and 30)
We have a pretty full deck this week with two Determinations and three Tribunal Decisions, one of which was litigated by our shop. It’s a fun-filled week with Walt Disney, South Korea addresses, haunted houses, Fourth Amendment and Eighth Amendment issues, and Native American tax free (or not) cigarettes – and only one of the decisions is on timeliness. So sit back and enjoy the show – don’t worry, unlike Frightworld (see below), we don’t have actors pushing you forward, compelling you to read faster.
TiNY Report for May 30, 2019 (reporting on DTA cases published May 23)
We weren’t on vacation last week. There was no TiNY Report because the DTA provided nothing on which we could report. Sometimes we write something quirky on those days when we have no cases, but last Thursday found both of the TiNY authors at Building 9 in Albany meeting with folks from the Tax Department on a case that could eventually become fodder for TiNY. And on Friday I found myself behind on my client work as a result of the Albany trip. So you got nothing, Spaulding, and you liked it!
TiNY report for May 16, 2019 (covering cases issued May 9)
This week we have one decision and two determinations – which is 1/3 of last week’s DTA output. But we figured we’d stick with last week’s theme of concluding each entry with one of the quotes from the American Film Institute’s “AFI’s 100 Years…100 Movie Quotes” – don’t worry, we’ll start with a new theme next week.
TiNY Report for May 9, 2019 (covering cases issued April 25 and 29 and May 2)
Today’s cases offer four (!) Tribunal decisions, one of which is on a case litigated by our shop. SPOILER ALERT! It did not go well (see the details below). Indeed, taxpayers were pretty much 0-9 for the week, so at least we had company. If you know math, you’ve probably already guessed that there are also a handful of ALJ Determinations, most of which address (gag) timeliness issues. This week, in our continuing effort to educate our readers (and entertain ourselves) on both New York tax developments and pop culture references, each of our entries concludes with a quote from the American Film Institute’s “AFI’s 100 Years…100 Movie Quotes.” Enjoy!
TiNY Report for May 2, 2019 (covering DTA cases issued April 25)
We’re back at it after a week with no cases posted by the DTA. We were taking bets on whether the person in charge of posting them was on vacation like everyone else (and not us). Anyway, we only have one determination and one order despite the week off. The order is on timeliness, but at least it is kind of interesting, so we go into more detail than usual – so buckle up!
TiNY Report for April 18, 2019 (covering DTA cases issued April 11)
Only one decision today, but it is a good one.
TiNY Report for April 11, 2019 (covering DTA cases issued April 4)
We have a Rugen-Handful of ALJ determinations on which to report today.
A Rugen what’s-that-now?
Let us digress. One of TiNY’s more memorable postings coined the phrase “hard-hearted Humperdink”. . . a reference comparing New York’s Audit Division to the Prince Humperdink character in The Princess Bride (1987). Anyway, Prince Humperdink’s consiglieri was Count Tyrone Rugen (played with delicious comedic malevolence by Christopher Guest) who had years earlier killed Inigo Montoya’s father in Montoya’s presence rather than pay the father for a custom sword the father had made for Rugen. This propelled Montoya on a twenty-year revenge-quest for Rugen so Montoya could utter “My name is Inigo Montoya. You killed my father. Prepare to die.” Right before he killed Rugen.
Why did Rugen need a custom-made sword? And how, after twenty years, did Montoya identify Rugen? The answer to both questions is the same: Count Rugen had six fingers on his right hand.
Which is just our long-winded way of saying there were six determinations this week. There are no orders and there’s nothing from the Tribunal.
And if you can’t get the image of Mandy Patinkin intoning “My name is Inigo Montoya. You killed my father. Prepare to die.” out of your head for the rest of the day, you’re welcome.
TiNY Report for April 4, 2019 (covering DTA cases issued March 28)
There are three determinations this week. One is the obligatory timeliness case, but the other two delve into taxes we don’t get to read about too often: The Article 9-A Franchise Tax and the Real Property Transfer Tax. Good times!