Mixed Research - NYS Tax Databases

NYS Tax Databases

Author: Dave
Date: 04.01.26 - 12:41am

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This project converts a scattered body of New York State tax materials into a structured research corpus: adjudicated decisions, Advisory Opinions, and Technical Services Bureau memoranda, all searchable through SQLite full-text indexing. The result is a practical research tool for examining how New York personal income tax law has actually been articulated and applied over time. :contentReference[oaicite:2]{index=2}

The real value of the dataset is that it makes pattern detection possible. Rather than relying on anecdote or isolated citations, users can measure outcome distributions, locate references to specific regulations, and evaluate how often particular sourcing or residency concepts appear across the published administrative record. :contentReference[oaicite:3]{index=3}

Database

Records

Date Range

Description

dta.db

5,926 cases

~1980–2026

All published ALJ determinations / Tax Appeals Tribunal

advisories.db

395 opinions

1980–2024

Personal income tax Advisory Opinions

memoranda.db

272 memos

1978–2018

NYS Technical Services Bureau Memoranda (TSB-M series)

2019 1 2020 13 2021 1 2024 14 ============================================================ PROCESSING TIME BY DECADE ============================================================ Decade Count Avg Months Min Max Median ------------------------------------------------------------ 1980s 114 5.7 1 34 4 1990s 112 7.3 0 105 3 2000s 79 7.4 1 28 6 2010s 58 10.4 1 36 9 2020s 1 42.0 42 42 42 ============================================================ SLOWEST 20 OPINIONS (most months to issue) ============================================================ 105 months [1996] TSB-A-96(5.1)I received 1991-01-18 issued 1999-10-21 105 months [1993] TSB-A-93(11.1)I received 1991-01-18 issued 1999-10-21 105 months [1993] TSB-A-93(3.1)I received 1991-01-18 issued 1999-10-21 105 months [1991] TSB-A-91(3.1)I received 1991-01-18 issued 1999-10-21 42 months [2020] TSB-A-20(7)I received 2017-03-24 issued 2020-09-29 36 months [2017] TSB-A-17(2)I received 2014-03-06 issued 2017-03-01 34 months [1985] TSB-A-85 (5)I received 1982-12-01 issued 1985-10-22 34 months [2018] TSB-A-18(3)I received 2015-10-29 issued 2018-08-29 28 months [1984] TSB-A-84 (2)I received 1982-06-17 issued 1984-10-08 28 months [2009] TSB-A-09(14)I received 2007-07-24 issued 2009-11-04 28 months [2015] TSB-A-15(3)I received 2013-01-09 issued 2015-05-12 28 months [2018] TSB-A-18(1)I received 2015-11-04 issued 2018-03-07 26 months [1984] TSB-A-84 (1)I received 1982-08-09 issued 1984-10-08 26 months [2016] TSB-A-16(5)I received 2014-06-02 issued 2016-08-31 23 months [1985] TSB-A-85 (2)I received 1983-07-08 issued 1985-06-06 22 months [2015] TSB-A-15(1)I received 2013-05-28 issued 2015-03-19 21 months [1986] TSB-A-86 (2)I received 1984-07-12 issued 1986-04-17 19 months [1985] TSB-A-85 (1)I received 1983-11-23 issued 1985-06-06 19 months [2000] TSB-A-00(5)I received 1999-02-26 issued 2000-09-06 19 months [2010] TSB-A-10(3)I received 2008-11-19 issued 2010-06-18 ============================================================ FASTEST 20 OPINIONS (fewest months to issue) ============================================================ 0 months [1992] TSB-A-92(1)I received 1992-04-03 issued 1992-04-20 0 months [1997] TSB-A-97(10)I received 1997-12-10 issued 1997-12-29 1 months [1981] TSB-A-81(4)I received 1981-06-08 issued 1981-07-15 1 months [1982] TSB-A-82(8)I received 1982-09-02 issued 1982-10-15 1 months [1983] TSB-A-83 (4)I received 1983-08-11 issued 1983-09-30 1 months [1984] TSB-A-84 (4)I received 1984-09-13 issued 1984-10-17 1 months [1986] TSB-A-86 (11)I received 1986-07-01 issued 1986-08-29 1 months [1987] TSB-A-87 (2)I received 1987-03-03 issued 1987-04-29 1 months [1988] TSB-A-88 (1)I received 1988-01-20 issued 1988-02-25 1 months [1988] TSB-A-88 (4)I received 1988-03-18 issued 1988-04-12 1 months [1991] TSB-A-91(4)I received 1990-12-11 issued 1991-01-29 1 months [1993] TSB-A-93(1)I received 1993-01-05 issued 1993-02-05 1 months [1993] TSB-A-93(4)I received 1993-03-17 issued 1993-04-29 1 months [1993] TSB-A-93(14)C, (8)I received 1993-05-03 issued 1993-06-18 1 months [1994] TSB-A-94(11)I received 1994-07-05 issued 1994-08-16 1 months [1997] TSB-A-97(3)C, (1)I received 1996-12-10 issued 1997-01-21 1 months [2009] TSB-A-09(10)C, (6)I received 2009-05-29 issued 2009-06-29 1 months [2013] TSB-A-13(5)C, (4)I received 2013-02-11 issued 2013-03-27 1 months [2018] TSB-A-18(2)I received 2018-06-06 issued 2018-07-11 2 months [1980] TSB-H-80(244)I received 1980-06-10 issued 1980-08-26 ============================================================ AVERAGE PROCESSING TIME BY YEAR (issued year) ============================================================ 1980 5.3 mo ##### 1981 4.5 mo #### 1982 4.7 mo #### 1983 6.0 mo ###### 1984 17.2 mo ################# 1985 17.1 mo ################# 1986 5.0 mo ##### 1987 3.8 mo ### 1988 3.9 mo ### 1989 3.7 mo ### 1990 4.5 mo #### 1991 11.5 mo ########### 1992 3.4 mo ### 1993 17.3 mo ################# 1994 3.7 mo ### 1995 4.2 mo #### 1996 14.0 mo ############## 1997 4.4 mo #### 1998 3.2 mo ### 1999 3.0 mo ### 2000 7.7 mo ####### 2001 7.2 mo ####### 2002 8.4 mo ######## 2003 6.6 mo ###### 2004 7.0 mo ####### 2005 11.2 mo ########### 2006 7.9 mo ####### 2007 4.0 mo #### 2008 6.2 mo ###### 2009 6.9 mo ###### 2010 6.5 mo ###### 2011 4.4 mo #### 2012 8.1 mo ######## 2013 9.6 mo ######### 2014 12.0 mo ############ 2015 15.4 mo ############### 2016 12.4 mo ############ 2017 24.0 mo ######################## 2018 19.8 mo ################### 2020* 42.0 mo ########################################## *The single 2020 timing datapoint reflects a petition submitted in 2017, prior to the cutoff. ============================================================ TREND SUMMARY ============================================================ Overall average across all years: 7.4 months Total opinions with timing data: 364 Average 1980-2000: 6.6 months (233 opinions) Post-2019: timing not observable

Comments: (2)

On 04.03.26 - 9:00pm dave wrote:

NYS Tax Databases: Outcome Statistics

A few people have asked about win rate numbers so here is the full outcome breakdown from dta.db.

Full Corpus Outcomes

Across all 5,926 published ALJ determinations and Tax Appeals Tribunal decisions:

Outcome Count %

division_won 3,363 57.3%

taxpayer_won 704 12.0%

mixed 566 9.6%

dismissed_procedural 557 9.5%

unknown 161 2.7%

motion_denied 145 2.5%

dismissed_jurisdiction 139 2.4%

dismissed 105 1.8%

remanded 73 1.2%

motion_granted 27 0.5%

unreviewed 19 0.3%

dismissed_moot 8 0.1%

The 12% taxpayer win rate is the all-in figure including procedural and jurisdictional dismissals. The more useful number for anyone deciding whether to litigate is the merits-only rate. Restricting to taxpayer_won + division_won + mixed gives 4,633 cases where substance was actually decided. Against that denominator: taxpayers won outright ~15% of the time, the Division ~73%, mixed ~12%.

Nonresident / Remote Work Subset

727 cases are flagged as involving nonresident sourcing, remote work, or the convenience of the employer rule:

Outcome Count %

division_won 460 63.3%

taxpayer_won 114 15.7%

mixed 86 11.8%

unknown 23 3.2%

dismissed_procedural 22 3.0%

remanded 7 1.0%

motion_denied 7 1.0%

dismissed_jurisdiction 5 0.7%

motion_granted 3 0.4%

On merits-decided cases in this subset (460 + 114 + 86 = 660): the Division prevailed in ~70%, taxpayers won outright ~17%, mixed ~13%. The Divisions win rate is slightly higher in nonresident/remote cases than in the general corpus, consistent with the Departments historically aggressive sourcing positions.

Note: the boolean flags driving this subset (is_nonresident_case, is_remote_work_case, is_convenience_rule) are regex-generated and not manually verified at scale. Reliable for triage but not exhaustive — some relevant cases will not be flagged.

show query

SELECT outcome, COUNT(*) as cnt FROM case_analysis WHERE is_nonresident_case = 1 OR is_remote_work_case = 1 OR is_convenience_rule = 1 GROUP BY outcome ORDER BY cnt DESC;

On 04.06.26 - 7:46pm Dave wrote:
I have filed a FOIL request for the missing 31 Advisory Opinion submission dates. Will add those if approved...

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