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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 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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Showing 48 posts from 2019.

TiNY Report for October 3, 2019 (reporting on DTA cases issued September 26)

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Only two determinations and one ALJ order as of this writing. The determinations were posted last week, but we like to give the litigants time to receive and read their determinations before we post our summaries, ergo our intentional delay. And for fun, this week we provide pop music quotes that are barely relevant to the cases.

TiNY Report for September 26, 2019 (reporting on DTA cases issued September 19)

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Every single Decision and Determination this week is a timy. So this week, instead of the TiNY Report, I think it is more accurate to call it the Timy Report.

Also, we noticed that Finding of Fact 1 of the four “Towers” determinations from last week still refers to a petition with “a United States Postal Service (USPS) postmark dated December 18, 2019.”  If that is a correct date, then USPS postmarks have been proven to be fallible. If that is not a correct date, then we can only assume that none of TiNY’s readers has reached out to the ALJ in those cases to let him know there is a typo.  

TiNY Report for September 19, 2019 (reporting on DTA cases issued September 12)

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This week we have four cookie-cutter Determinations.  I am going to give cookie-cutter summaries.  You need read only one of the summaries since they are all the same.  In the past, I would write one summary and then write “ditto” for each of the subsequent cases, but I have recently discovered that our website allows you to search TiNY for our summaries; so henceforth, I will provide summaries for all cases instead of saying “see above.”  And yeah, this is the second time this decade I used “henceforth” in a sentence.  I try to avoid anachronistic words and phrases, but I guess my guard was down this week.  Mea culpa.

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.