There were three determinations to report on this week, and a majority of them are not Timies! The two substantive cases address how to properly source income from a trade, business, or profession carried on, or previously carried on, in New York under Tax Law § 631. And in both cases, the Judges found that such sourcing needed to follow the path set forth in applicable regulations as required by the statute.
I didn’t watch any of the Olympics other than the part of the closing ceremonies when they cut from Paris to LA. But I heard that break dancing was an Olympic event in Paris for the first time – but it’s already been axed for the next Summer Games. Wow. Since the Summer Olympics are going to LA in 2028, maybe they can have an Olympic event like the contest at the end of “Eight Mile” when B-Rabbit resorts to a self-deprecating rap to dispatch Papa Doc. I liked that, so I’d probably watch something like that again. And like in Eight Mile, shouldn’t the audience (maybe the TV audience to avoid host-country bias) participate in the judging of certain Olympic events?
The IOC knows where to find me if it needs more suggestions.
The mental conversation I just conducted with myself:
“What should I write today about this TiNY Report being late again?”
“How about the truth? You have been diverting your non-billable attentions to the summer because ‘summertime is running out’ and ‘supplies are limited.’”
“No one cares about your personal life. How about ‘no excuses” since you have no excuses.”
“The Alice in Chains song ‘No Excuses?’ That’s a good one. For some reason that song reminds me of the Blues Traveler tune ‘The Mountains Win Again.’"
“Wow. 90s much?”
“Shut up.”
“No, you shut up.”
(nothingness)
We present a bunch of pent-up case summaries today, only a few of which have a worthwhile tale to tell. For my money (ed.: there’s actually no money involved) I recommend Saslaw, in which a pro se petitioner won a difficult responsible officer case; Rockaway Realty Associates, involving a local mortgage recording tax refund claim (a unicorn of a case if ever there was); and Lynch, discussing the limitation in the “548-day rule” prohibiting spouses from remaining in New York during the relevant period.