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Noonan’s Notes Blog

About This Blog

Noonan’s Notes Blog is written by a team of Hodgson Russ tax attorneys led by the blog’s namesake, Tim Noonan. Noonan’s Notes Blog regularly provides analysis of and commentary on developments in the world of New York and multistate tax law. Noonan's Notes Blog is a winner of CreditDonkey's Best Tax Blogs Award 2017.

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Timothy Noonan 
Ariele Doolittle
Joseph Endres
Daniel Kelly
Elizabeth Pascal 
Craig Reilly
Andrew Wright 

Showing 2 posts from March 2018.

What is considered a “Permanent Place of Abode?”

New Tribunal Case Offers Up a New Framework for Answering this Question

New York’s two-part test for statutory residency has been heavily litigated over the years, and one of the biggest issues has involved the determination as to whether a taxpayer maintained a “permanent place of abode.” In 2014, the State’s highest court in Gaied v. NYS Tax Appeals Tribunal struck down the Tax Department’s overly-broad interpretation of “permanent place of abode” in favor of a more sensible interpretation. In doing so, the High Court declared that in order for a place to constitute a permanent place of abode (“PPA”), “there must be some basis to conclude that the dwelling was utilized as the taxpayer’s residence.” And later in the decision, the Court opined that to qualify as a PPA, “the taxpayer must, himself, have a residential interest in the property”

Tax Department Extends Some Filing Deadlines Due to Nor’easter

By on

Governor Andrew Cuomo declared a State Disaster Emergency for counties affected by the March 2018 Nor’easters that began early this month. If you hadn’t heard the term before, a nor’easter is a large cyclone usually accompanied by heavy rain or snow that can cause hurricane-force winds, blizzard conditions, and coastal flooding. To us folks in Buffalo, we also call this “Tuesday.”

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