In an opinion issued on May 15, 2025, the State of New York Tax Appeals Tribunal, the highest administrative forum for state tax appeals, upheld the application of the state’s income tax “convenience rule” imposing New York tax on wages earned by a New York City law school professor while he worked from his Connecticut

The November 30, 2023, opinion of a New York administrative law judge in In the Matter of the Petition of Edward A. and Doris Zelinsky upholds the state’s so-called income tax “convenience rule” with an expanded legal rationale that New York employers with remote and hybrid employees outside of New York State will want to