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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Posts from July 2023.

According to, the most covered pop song of all time is “Yesterday” by the Beatles. The most covered DTA issue is “Timy,” and this week’s rendition comes from a new voice (at least new to me), Judge Alexander Chu-Fong. His version sounds a lot like all the other versions I’ve heard. 

Constant reader:  Your TiNY correspondent was vacationing in Kingston, Ontario, Canada, last weekend. And I decided to not risk the wrath of Correspondent Spouse by working on TiNY during my time away. But now I am back. And … there were an order and two ALJ determinations posted. The order is not your ordinary timy, one of the determinations is a very ordinary timy, and the other determination involves a sales tax license revocation dispute.  

A Tribunal Decision and an ALJ Determination were posted last week. 

With respect to the Tribunal decision, in its write-up of the ALJ’s determination, TiNY provided the Tribunal with a road map to reverse what seemed to me to be (with due respect to the ALJ) an errant grant of summary determination. But, I guess my analysis was wrong (hey, it happens). 

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