Tax

New York Banking & Finance Contract Interpretation Tax

Appellate Division, Third Department

Uncategorized

Matter of Sunoco v. Tax Appeals Tribunal — Oil swaps are inventory exchanges, not sales receipts

/ July 25, 2026

The Third Department upheld New York’s treatment of Sunoco’s paired petroleum buy/sell transactions as inventory exchanges rather than franchise-tax receipts.

New York Civil Procedure Employment Tax

Appellate Division, Third Department

Uncategorized

Matter of Paychex v. Taxation and Finance — PEO tax challenge is premature

/ July 25, 2026

The Third Department dismissed Paychex’s challenge to New York’s PEO franchise-tax rules because the audit had not produced final agency action and the regulations were not retroactive.