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2019-2 N.Y. Tax Cas. J-321 (2019)

handle is hein.nytax/nytcas0085 and id is 1 raw text is: 2019 New York Tax Cases J-321 STATE OF NEW YORK DIVISION OF TAX APPEALS In the Matter of the Petition of DETERMINATION LISA AND MITCHELL SOLOMON DTA NO. 828076 for Revision of a Determination or for Refund of Real Estate Transfer Tax under Article 31 of the Tax Law for the Period March 6, 2015. Petitioners, Lisa and Mitchell Solomon, filed a petition for revision of a determination or for refund of real estate transfer tax under article 31 of the Tax Law for the period March 6, 2015. Petitioners, by their representative, Bryan J. Farrell, Esq., brought a motion filed on October 24, 2018, seeking summary determination in the above-referenced matter pursuant to Tax Law § 2006 (6) and 20 NYCRR 3000.9 (b). The Division of Taxation appeared in opposition to the motion by its representative, Amanda Hiller, Esq. (Jennifer L. Hink-Brennan, Esq., of counsel). The parties completed their submissions on January 4, 2019, which date began the 90-day period for issuance of this determination. After due consideration of the motion, the supporting affidavits of Bryan J. Farrell, Esq., Joseph G. Farrell, Jr., and Jane R. Kratz, Esq., and supporting exhibits, the Division of Taxation's memorandum in opposition, affidavit of Theresa A. Carucci and supporting exhibits, and all the pleadings and proceedings had herein, Donna M. Gardiner, Administrative Law Judge, renders the following determination.

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