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Printer-friendly version Download vCard Christopher L. Doyle Direct tel: 716.848.1458 cdoyle@hodgsonruss.com Partner, Practice Group Leader State & Local Tax Practice Group Buffalo Office

Areas of Practice: Taxation law

Professional Experience: Mr. Doyle is a partner in the Firm's State & Local Tax practice and a past instructor of Tax Practice and Procedure at the University of Buffalo School of Management.

Presentations/Articles: Articles on New York taxation that Mr. Doyle authored or co-authored have appeared in accounting and legal journals. He has spoken frequently for the Foundation for Accounting Education and is currently one of the organization's featured lecturers. Mr. Doyle has also made presentations to the Tax Executives Institute, the Committee on State Taxation, the Canadian Association of Importers and Exporters, the Canadian Tax Foundation, and the Council for International Tax Education.

Publications: He is the author of "New York's Energy Taxes: Recent Interpretations Provide Little Light, No Heat," State Tax Notes; "Fundamentals of New York State and City Taxation;" and the New York State chapter of the Tax Analysts' Guide to State Taxation. He is also contributing editor to New York Tax Highlights and co-author of the New York State chapter of CCH's Business Incentives Guide.

Significant State Tax Representations: Mr. Doyle served as lead counsel with respect to the following published state tax decisions:

• Tennessee Gas Pipeline Co. v. Urbach, 726 NYS 2d 350 (Court of Appeals, 2001) - New York's Natural Gas Import Tax declared unconstitutional.
• Matter of Premier National Bancorp, (NYS Tax Appeals Tribunal August 2, 2007) - Aggressive use of "grandfathered Article 9-A subsidiaries" to reduce a bank's New York franchise tax may be permitted.
• Matter of General Electric Company (NYS ALJ May 15, 2003) - The sales tax (and not the use tax) applies to natural gas delivered to a purchaser in New York.
• Suburban Carting Corp. v. Tax Appeals Tribunal, 694 NYS 2d 211 (3d Dept 1999) - Tracing may be used to directly attribute expenses for franchise tax purposes.
• Matter of Stat Equipment Corp., (NYS Tax Appeals Tribunal January 25, 1996) - Ambulance company is not subject to the Article 9 franchise tax on transportation corporations.
• Matter of Manufacturers and Traders Trust Company (M&T Bank), (NYS Tax Appeals Tribunal September 23, 2004) - Through-the-wall ATMs may be capital improvements to real property and thus may be purchased on an installed basis free from sales tax.

Professional Associations: Past co-chair, Buffalo Institute on Taxation

Bar Associations: Past chair, Taxation Committee of the Bar Association of Erie County

Admitted to Practice: New York

Education:
B.A., Bowdoin College
J.D., cum laude, University at Buffalo Law School, State University of New York