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2025-2 N.Y. Tax Cas. J-1 (2025)

handle is hein.nytax/nytcas0097 and id is 1 raw text is: 






                              2025  New  York Tax Cases
                                          J-1




STATE  OF  NEW  YORK

DIVISION  OF  TAX  APPEALS


               In the Matter of the Petition

                           of
                                                                  DETERMINATION
              CIIANDRAMATTIE SINGH:                               DTA  NO.  850216

for Redetermination of a Deficiency or for Refund of New
York State Personal Income Tax under Article 22 of the
Tax Law for the Year 2017.


      Petitioner, Chandramattie Singh, filed a petition for redetermination of a deficiency or for

refund of New York State personal income tax under article 22 of the Tax Law for year 2017.

      A formal hearing was held before Barbara J. Russo, Administrative Law Judge, in

Brooklyn, New York, on April 17, 2024, at 12:00 p.m., with the final brief to be submitted by

July 31, 2024, which date began the six-month period for the issuance of this determination.

Petitioner appeared pro se. The Division of Taxation appeared by Amanda Hiller, Esq. (Daniel

Schneider, Esq., of counsel).

                                        ISSUE

      Whether petitioner has established that the Division of Taxation improperly denied her

claim for refund of personal income tax for the year 2017, on the basis that the claim was filed

after the expiration of the period of limitations.

                                 FINDINGS OF FACT

      1. On March  3, 2018, petitioner, Chandramattie Singh, electronically filed a New York

State resident income tax return, form IT-201, for the year 2017 (return). Petitioner reported

$25,056.00 of New York adjusted gross income and New York State tax of $470.00 on the

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