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Statutory Interpretation › State Taxes › Tax Appeals

Cozen O'Connor

Exception to General Refund Limitations Period for PA Corporate Net Income Tax for Report of Change

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In an unusually taxpayer-friendly decision, a three judge panel of the Pennsylvania Commonwealth Court concluded that Section 406 of the Tax Reform Code of 1971 (the code), 72 P.S. § 7406, is an exception to the general...more

Blank Rome LLP

Internet Tax Freedom Act Preempts New York’s Imposition of Tax

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The New York State Tax Appeals Tribunal, affirming an Administrative Law Judge, held that the Internet Tax Freedom Act prohibits the Division of Taxation from subjecting to tax the receipts that Verizon New York, Inc....more

Blank Rome LLP

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

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In a recently released, nonprecedential decision, the California Office of Tax Appeals (“OTA”) upheld a sales tax assessment of nearly $1 million against an owner/operator of dental practices,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

Vorys, Sater, Seymour and Pease LLP

Scope of Ohio Commercial Activity Tax Agency Exclusion Remains Unsettled Following Ohio Supreme Court’s Decision in Aramark Corp....

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Aramark provided food service operations to various clients (e.g., hospitals, universities, corporations, sports arenas, etc.). The clients paid Aramark a management fee. In addition, the clients reimbursed Aramark for the...more

Vorys, Sater, Seymour and Pease LLP

Ohio Supreme Court Doubles Down on Applying a Plain and Ordinary Meaning to Sales Tax Exemptions

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On August 13, 2025, the Ohio Supreme Court overturned the Ohio Board of Tax Appeals (BTA) and the Ohio Tax Commissioner in Claugus Fam. Farm, L.P. v. Harris, 2025-Ohio-2807, Slip Opinion No. 2025-Ohio-2807, thereby allowing...more

Morgan Lewis

Los Angeles ‘Mansion Tax’ Update Regarding Office of Finance Assessments

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Taxpayer disputes involving Los Angeles’s Measure ULA, the Homelessness and Housing Solutions Tax—commonly referred to as the “mansion tax”—are progressing through the city’s administrative review process. Property owners...more

Kilpatrick

4 Key Takeaways | Market Based Sourcing and Discretionary Adjustments

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On April 24th, Kilpatrick tax partner Jeff Reed presented during a New York City Bar SALT Committee meeting. Jeff discussed the recent Jefferies Group LLC & Subsidiaries New York Tax Appeals Tribunal decision....more

Pullman & Comley, LLC

Jurisdiction 101: Connecticut Supreme Court Hands Down Win For Taxpayers

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In a victory for taxpayers across the nutmeg state, the Connecticut Supreme Court recently held in 7 Germantown Rd., LLC v. City of Danbury, No. 21024, 2025 WL 309848 (Conn. Jan. 28, 2025) (“Germantown”) that the appraisal...more

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