In This Issue:
Gain on Sale of Non-New York Leaseholds Held Properly Sourced to New York Based on Business Allocation Percentage; Tribunal Reverses Dismissal and Allows Case to Proceed Before ALJ; Federal Court Dismisses Challenge to Tax Penalties Under Comity; When Does Interest Start to Run on a Tax Refund?; and Insights in Brief.
Excerpt from Gain on Sale of Non-New York Leaseholds Held Properly Sourced to New York Based on Business Allocation Percentage -
A New York State Administrative Law Judge held that a nonresident shareholder in a corporation that elected New York S corporation status should have included his pro rata share of the gain from the S corporation’s sale of four Pennsylvania leasehold interests in his New York source income, based on the S corporation’s business allocation percentage. Matter of Steven E. Breitman, DTA No. 824268 (N.Y.S. Div. of Tax App., Aug. 1, 2013).
Please see full issue below for more information.
Firefox recommends the PDF Plugin for Mac OS X for viewing PDF documents in your browser.
We can also show you Legal Updates using the Google Viewer; however, you will need to be logged into Google Docs to view them.
Please choose one of the above to proceed!
LOADING PDF: If there are any problems, click here to download the file.