Hodgson Russ SALT Dispatch

From TiNY:  We interrupt our not-so-regularly-scheduled … umm … schedule for a special report by our court-watch correspondents: Open Weaver Banks and Tim Noonan. I’m sure all our readers are familiar with Open as a result of her recent article “Do cross border incursions by extraterrestrial drones implicate New Jersey Use Tax?” But you may not be so familiar with Tim since he tends to keep a low profile. 

All kidding aside, Happy Holidays from TiNY! As a special holiday treat, here is Open and Tim’s take on the November oral argument before the Tax Appeals Tribunal in Matter of Zelinsky (with some parenthetical commentary by TiNY). Zelinsky may end up being one of the most important SALT cases addressing the unique SALT circumstances resulting from the COVID-19 pandemic, and Judge DiFiore’s determination against Petitioner may be found here. Professor Zelinsky knew of our firm’s interest in convenience rule disputes and was kind enough to share a copy of the transcript of the Tribunal argument.