Noonan’s Notes Blog

The Third Department of the New York Supreme Court, Appellate Division recently issued a somewhat surprising ruling that should expand taxpayers’ access to protest rights within the state’s Division of Tax Appeals (“DTA”).

In the case, Matter of Dumpling Cove, LLC, the Petitioner was audited and subsequently signed a Statement of Proposed Audit Change in January 2018, agreeing that it owed over $500,000 in sales tax, interest, and penalties. Shortly thereafter, the Petitioner made a partial $100,00 payment, and the Department responded with a letter confirming ...