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State and Local Tax Blog

About This Blog

Taxes in New York (TiNY) is a blog by the Hodgson Russ LLP State and Local Tax Practice Group. The weekly reports are intended to go out within 24 hours of the Division of Tax Appeals’ (DTA) publication of 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.  

TiNY Report for September 12, 2019 (reporting on DTA cases issued August 27 and September 5)

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This week we have seven Orders and two Tribunal Decisions that were posted after we went to press last week.  I doubt that any of these will be talked as much about Matter of Obus which we wrote about two weeks ago here and our fellow blogger at Noonan’s Notes wrote about here.

TiNY Report for September 5, 2019 (reporting on DTA cases issued August 29)

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Today we have four determinations and two orders, only one of which is a timy.  Not a bad way to ring in the new school year.

TiNY Report for August 29, 2019 (reporting on DTA cases issued August 22)

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Today we report on three determinations. Two are quick-hitters. One requires a little more analysis.

TiNY Report for August 22, 2019 (reporting on DTA cases issued August 15)

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After two weeks with sparse output from the DTA, we should have realized that it would ramp back up at some point. This week we have two decisions and seven determinations.

TiNY Report for August 15, 2019 (reporting on a DTA Order issued August 8)

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As of this writing, there’s nothing posted by the Tribunal and the ALJs have posted only one Order.  Not only is it a “timy,” but it’s a timy-squared!

TiNY Report for August 8, 2019 (reporting on DTA cases published August 1)

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I guess the DTA decided to embrace the summer slow-down this week after pumping out so many decisions and determinations last week.  There’s just one determination this week, and it’s not particularly noteworthy, but at least it’s not a timy.

TiNY Report for August 1, 2019 (reporting on DTA cases published July 24 and 25)

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We’re in the “Dog Days” of summer now. But you wouldn’t know it from the DTA’s output, which this week includes three Tribunal decisions and four ALJ determinations. There’s a timie or two, but the cases addressed mostly substantive issues, and Matter of Catalyst Repository Systems, Inc. is a noteworthy decision.

TiNY Report for July 25, 2019 (covering cases issued July 18)

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There are three determinations and one order this week.  And guess what?  They are all timies – I’ve decided that I will also appropriate this word because it has a nice ring to it.  I’d also like to make a quick note of admiration for the thoughtful approach the ALJ’s applied to these cases.  It would be easy for the judges to just go through the motions on these mind-numbing timies.  But as you will see below, there is nothing superficial about the analyses applied. 

TiNY Report for July 18, 2019 (covering cases issued July 11)

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As of this writing, three Determinations and one ALJ Order. No “timies.” Being an author brings almighty powers. Case in point - I just created a word: timy \tīm-ē\ n. (2019): a division of tax appeals order, determination or decision involving the issue of whether a taxpayer filed their request for conciliation conference, petition for administrative law judge hearing or an exception to the tax appeals tribunal within proper time limits. pl.: timies. 

TiNY Report for July 11, 2019 (reporting on DTA cases published June 27)

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The DTA (like the rest of us) had the July 4th holiday off.  But there were two Tribunal decisions published after we went to press before the holiday that we’ve been sitting on.