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State and Local Tax Blog

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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.  

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Photo of State and Local Tax Blog Christopher L. Doyle
Partner, State & Local Tax Practice Leader
cdoyle@hodgsonruss.com
716.848.1458
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Chris is in the firm's State & Local Tax (SALT) Practice. His practice spans most tax matters, but focuses primarily on New York State and New York City business taxes …

Showing 144 posts by Christopher L. Doyle.

TiNY Report for December 2, 2022

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Loyal Readers: There are no cases on which to report this week, but it  looks like I missed an ALJ Determination decided November 17 when I prepared last week’s report. It is summarized below. 

TiNY’s Post-Thanksgiving DTA Update

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My Thanksgiving dinner is mostly-digested and the snow on my lawn has mostly-melted.  It is back to my regularly-scheduled programming, and this week my visit to the Division of Tax Appeals' website disclosed that the Tribunal posted two decisions and the ALJs issued three orders.

TiNY Report for November 11, 2022

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Update on DTA cases for 11/11/22

TiNY Report for November 4, 2022 (Reporting on DTA Cases Issued September 22 and September 29)

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TiNY is back with commentary and analysis on another group of DTA cases.

TiNY Report for DTA Cases Issued Since October 12, 2022

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TiNY is back after a brief public sabbatical! In this blog, we're taking a look at three weeks worth of recent cases.

TiNY Report for April 8, 2021 (reporting on DTA cases issued March 24 and April 1)

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For your consideration, constant reader: a Tribunal decision on a cigarette tax possession penalty and three ALJ timies. The timies are all dated April 1, and contain a footnote that has, in the past, been a trigger for sarcastic comments by yours truly. Normally I am not gullible enough to fall for April Fool’s Day scams, and I think the Supervising ALJ may be baiting me. But I respect him too much to not take the bait. He is Santiago from The Old Man and the Sea, and I am a ginormous marlin. So, let’s start with this:

Under the headline, “Say it ain’t so, Yehad!,” the Albany Times Union reported this weekend that Mr. Abdelaziz was not permitted to represent petitioners before the DTA. The article quotes “knowledgeable sources” and all three of the Determinations issued on April 1 as confirmation. The article also noted that Mr. Abdelaziz has been denied the opportunity to represent petitioners before the DTA several times in the past.

TiNY Report for March 25, 2021 (reporting on DTA cases issued March 11 and 18)

Greetings constant reader. The TiNY editorial staff is healthy, in the course of being vaccinated, and looking forward to things loosening up so we can actually appear before the DTA in the near future. Well . . . at least two of us are. I am actually wondering how a Judge will react to my request for an adjournment based on my inability to fit into any of my suits. Is that reasonable cause? I sure as heck hope so. Because I sure as heck have that problem right now.

TMI? There is no such thing at TiNY.

This week we have eight determinations on which to report.

TiNY Report for March 19, 2021 (reporting on DTA cases issued since February 28)

In this edition, we recall the Bard’s Julius Caesar because, you know, the whole “ides of March” thing. And so: “Friends! New Yorkers! Twelve (or so) loyal readers! Lend me your eyes.”

In Shakespeare’s play, the Soothsayer warns Caesar: “Beware the ides of March.” TiNY would have instead cautioned petitioners: “Beware the first of March” –  because in the four Tribunal Decisions issued on March 1, no petitioner was victorious. But, consistent with Marc Antony’s sarcastic eulogy of Caesar: Joe Endres, Emma Savino, and I write to report the decisions, not to praise them. And yet TiNY is an honorable institution (or so we’d like to think).

Et tu, IBM?  Yup. On March 5, the Tribunal issued another Decision and another taxpayer defeat. An ALJ Order rounds out our presentation.

TiNY Report for March 1, 2021 (reporting on DTA cases issued February 18)

If you like sales tax (and/or the musings of our sales tax correspondent, Joe Endres) you are going to be in hog heaven this week. Of the five ALJ Determinations posted, three involve substantive sales tax issues. There is so much sales tax this week that I have stepped in to summarize one of the Determinations. They say March comes in like a lion. So true!