Taxes in New York (TiNY) is a blog by the Hodgson Russ LLP State and Local Tax Practice Group members Chris Doyle, Peter Calleri, and Zoe Peppas. The weekly reports are intended to go out every Tuesday after the New York State Division of Tax Appeals (DTA) publishes 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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Posts from November 2024.

There are an order and two determinations this week for your thoughtful consideration. The order refers to 36 separately numbered allegations of error by the Division. And, because I am of a certain age and it is Thanksgiving season, this triggered a memory of “Alice’s Restaurant Massacree” by Arlo Guthrie. The song was notable for its 1960s anti-establishment narrative and wry humor. It also took up one whole side of an album. For the benefit of you kids out there, albums were round vinyl media for delivering permanently embedded audio content. Back in the day, most album sides had between five to seven songs making up roughly 22 minutes of audio. In the 1970s and 1980s, we dinosaurs would re-record both sides of an album onto the single side of a 90-minute cassette tape so we could have two albums’ worth of music on one tape to play in our cars since there was no easy way to play a vinyl album in a moving vehicle.   

TiNY has been off the air for the last few weeks while waiting for the DTA to provide enough content for us to prepare a Report with critical mass. Cases have been dribbling out recently, and over the last three weeks, there is just one Tribunal decision and one ALJ determination on which to report. We had hoped for more this week and were disappointed.

Still, the Decision and Determination were not process cases (i.e., neither case involved timeliness or other jurisdictional issues). So, at least there is some substance there.

The next TiNY Report will be post-election. Thank goodness. Talking heads of all stripes are launching their partisan grenades at a frequency that is impossible to ignore. Your editor yearns for simpler times when 95% of the news he needed came from the Weather Channel, ESPN, Tax Notes, Weekend Update, and the DTA website. 

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