Joshua Sivin

Blank Rome LLP

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California Office of Tax Appeals Denies Occasional Sale Exemption from Sales Tax to Dental Practice

In a recently released, nonprecedential decision, the California Office of Tax Appeals (“OTA”) upheld a sales tax assessment of nearly $1 million against an owner/operator of dental practices, finding that the sale of the...more

8/25/2025 / Asset Purchase Agreements , California , Exemptions , Regulatory Oversight , Sales & Use Tax , State Taxes , Statutory Interpretation , Tax Appeals , Tax Liability

Deli’s Party Platters Found Subject to Sales Tax Despite Customer Assembly Required

In the world of sales tax, the devil is often in the details. A recent decision from the New York State Tax Appeals Tribunal (“Tribunal”) serves as an example of how seemingly insignificant details can determine whether a...more

4/18/2025 / Administrative Law Judge (ALJ) , Audits , Business Entities , Government Agencies , New York , Sales Tax , State Taxes , Tax Appeals , Tax Liability , Tribunals

New York ALJ Finds Convenience of Employer Rule Applicable to Nonresident but Provides a Roadmap for How a Taxpayer May Prove the...

In another challenge to New York’s so-called convenience of the employer rule (the “convenience rule”), an Administrative Law Judge (“ALJ”) recently issued a determination upholding application of the rule against a...more

10/23/2024 / Administrative Law Judge (ALJ) , Income Taxes , New York , State Taxes , Tax Appeals , Tax Liability

NY Appellate Court Finds That IBM Cannot Deduct Foreign Royalty Payments

A New York intermediate appellate court upheld a New York State Tax Appeals Tribunal determination finding that International Business Machines Corp. and its combined affiliates (together, “IBM”) improperly deducted royalty...more

4/21/2023 / Foreign Affiliates , Royalties , State Taxes , Tax Liability

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