TiNY Report for July 18, 2023

Constant reader:  Your TiNY correspondent was vacationing in Kingston, Ontario, Canada, last weekend. And I decided to not risk the wrath of Correspondent Spouse by working on TiNY during my time away. But now I am back. And … there were an order and two ALJ determinations posted. The order is not your ordinary timy, one of the determinations is a very ordinary timy, and the other determination involves a sales tax license revocation dispute.  

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TiNY Report for July 11, 2023

A Tribunal Decision and an ALJ Determination were posted last week. 

With respect to the Tribunal decision, in its write-up of the ALJ’s determination, TiNY provided the Tribunal with a road map to reverse what seemed to me to be (with due respect to the ALJ) an errant grant of summary determination. But, I guess my analysis was wrong (hey, it happens). 

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Tiny Report for June 27, 2023

I may be turning into a crabby old man.

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TiNY Report for June 13, 2023

The best thing I can write about the DTA’s production this week is that I get to use both of the words TiNY has created in the same sentence. This week there is one Tribunal decision and one ALJ determination, and they are a timy and a costy, respectively. And, as Forrest Gump once mused, that’s all I have to say about that.

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TiNY Report for June 2, 2023

“It is a truth universally acknowledged, that a lawyer in possession of extra time, must be in want of a blog.”

And with that paraphrase, I welcome you, constant reader, to the “Pride and Prejudice” edition of TiNY.

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TiNY Report for June 1, 2023

I expressed a lack of sympathy for the plight of the petitioners involved in the cases I summarized last week. As I started reading through this week’s DTA production, my thinking was much more “on brand.” I am, after all, on “Team Taxpayer,” and I tend to revert to that norm absent some really annoying taxpayer antics. Anyway, I was easing back into my pro-taxpayer comfort zone when I read the last determination summarized below, and BAM!, I was blown right back into wondering just what-the-heck some Petitioners are thinking. And, not for the first time, I wondered whether the $500 frivolous pleading penalty is really a big enough deterrent.

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TiNY Report for May 22, 2023

There were two determinations posted by the DTA on May 18, 2023. 

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TiNY Report for May 16, 2023

I missed posting the May 4 edition of TiNY. I summarize the three timies that hit the DTA’s website on “Star Wars Day,” below.  I couldn’t cover those cases that week because I was too busy helping the Hodgson Russ  team get out our Alert on the revenue portions of the 2023-24 State Budget enacted during the first few days of May. And since TiNY is all about the Division of Tax Appeals, let me offer this slice of that Budget Alert:

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TiNY Report for April 28, 2023

This week the DTA posted three ALJ Determinations. What recent popular culture moment involves three? How about this week’s episode of “Ted Lasso” (SPOILER ALERT!) in which he informs the team of the four key aspects of the Total Football strategy the team is adopting? The four aspects are conditioning, versatility, awareness, and a fourth to be determined. So, really there are only three, at least for now. In any case, our theme for this week’s TiNY is borrowed from Coach Ted.

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TiNY Report for April 13, 2023

Sorry, loyal readers, but client work takes precedence, and I had a load these past few months. In addition, we have been hiring and training new colleagues here to be able to serve the rising tide of clientele seeking to move out of New York, or who are being audited merely because they had the temerity to move out of New York. And New Yorkers are not the only folks who feel disrespected by the internal tax laws of their states of residence; our residency client-base in states like California, Connecticut, Illinois, Massachusetts, and New Jersey has been growing too.

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