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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.  

Blog Disclaimer

TiNY Report for December 5, 2019

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We are easing into the holiday season here, which is to say that we are trying to get as many things as humanly possible wrapped-up so we may better address the inevitable year-end client emergencies. The DTA is being a team player by not posting many decisions/determinations/orders. Indeed, there is nothing new on the DTA’s website as of this writing. That said, we’ll check the DTA’s website over the next few days to make sure it didn’t pull the old switcheroo on us and decide to start posting on Fridays.

This week is an ideal time to repost our “Disclaimer.” A link to our Disclaimer is always at the bottom of our TiNY webpage, but we expect it is rarely read. So, during slow news weeks like this, we sometimes post the Disclaimer so all of our readers understand TiNY’s limitations. In short: You shouldn’t rely on TiNY Reports for anything other than a quick overview of the cases addressed.

And now, the fine print:


Taxes in New York (“TiNY”)  is published and presented by Hodgson Russ LLP, which is a law firm. It is presented for general informational and entertainment purposes only and should not be construed as legal advice or legal opinion on any specific facts or circumstances. Although it should go without saying, we are compelled to tell you that your receipt of this document does not make us your lawyers. Hodgson Russ LLP will not establish an attorney/client relationship with you without first corresponding with you and sending you an engagement letter signed by one of our lawyers. If you have not received a signed engagement letter, you are not our client. Period.

In any event, you’d be wise to not rely on what is written here. In striving for a pithy and easy-to-read presentation, the authors may make sweeping legal statements like "the holding was…" or "the law is…," when what we really mean is "at this time we interpret that the court construed the law to apply in the following way…" or "at this time we understand that the government folks who administer these taxes for a living—and with whom we often disagree—think the law should be applied in the following way… ." In short, the authors may have sacrificed a little accuracy in favor of brevity and readability. Furthermore, some of what we write here may be humor, sarcasm, satire, hyperbole, etc., which has no basis in fact or law but is included purely for entertainment purposes or to make a point. We are lawyers with a diverse client base; so we won't admit that anything stated in TiNY Reports is 100 percent reliable, since we don't want to end up eating those words in some future situation in which we wish to take a contrary position on behalf of a client.  Accordingly, we won't cite TINY Reports in support of any position we are trying to prosecute or defend, and you shouldn't either.

Information contained here is almost certainly inapplicable to your particular facts or situation; please consult an attorney (you can find the biographies of many of our favorites at for specific advice applicable to your situation. Hodgson Russ LLP is not responsible for errors in the TiNY Reports, and will almost certainly disavow the authors if we have written something here that a significant number of readers find offensive. Hodgson Russ LLP is likewise not responsible for readers who misconstrue the authors’ attempts at humor or satire as reality, or misinterpret any statements here or in the presentation of these materials as reflective of the authors' sincere and immutable opinions. That said, this disclaimer is sincere. And immutable (for now, anyway).

Finally (hooray!) we must admit that another reason we author and present the TiNY Reports is that we hope you’ll be impressed by our knowledge of the state and local tax matters on which we chose to write. In that sense, this material may be considered attorney advertising under the rules of certain jurisdictions in which Hodgson Russ lawyers practice (such as in Ontario, Canada, where certain of our attorneys are Licensed Foreign Legal Consultants, and in the states of New York, Connecticut, New Jersey and Florida). But if you have read this far, we think it is unlikely you’d be foolish enough to hire a lawyer based on an advertisement. So we welcome your further inquiries into our qualifications and experience.

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