The main areas
State and local tax, often called SALT, covers income taxes on individuals and businesses, sales and use tax, property tax, and a range of specialized taxes. New York State, New York City, and other localities each impose their own taxes, administered by different agencies, including the New York State Department of Taxation and Finance and the New York City Department of Finance. Residency audits examine whether a person who claims to have moved remained domiciled in New York, or spent enough time in the state while keeping a home here to be taxed as a resident. Since the Supreme Court allowed states to require remote sellers to collect sales tax based on economic activity, many businesses have collection duties in states where they have no physical presence.
When business taxes become personal
Some state taxes can follow individuals. In New York, officers, owners, and employees who are responsible for collecting and remitting sales tax can be held personally liable for unpaid sales tax, even after the business has closed. Withholding taxes on wages can raise similar responsibility questions. Records of who signed returns, who controlled bank accounts, and who decided which bills to pay are central to these disputes. The federal deduction for state and local taxes, also called the SALT deduction, is a separate topic; its limit was raised for several tax years by 2025 federal legislation, and how it applies depends on income and filing status.
Disputes and where they go
New York tax disputes follow their own path. After an audit, a notice of determination or deficiency can be challenged through a conciliation conference at the Bureau of Conciliation and Mediation Services or by a petition to the Division of Tax Appeals, and these options have short deadlines. A determination by an administrative law judge at the Division of Tax Appeals can then be reviewed by the Tax Appeals Tribunal and, after that, in the state courts. City taxes have a separate New York City Tax Appeals Tribunal, and property tax assessments follow a separate process. We review the notice, the audit file, and your records to decide which forum fits and what evidence to build.
