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Paychex v. New York: Procedure before substance
In this episode of the SALT Shaker Podcast, hosts and Partners Jeremy Gove and Chelsea Marmor discuss the New York Appellate Division's recent decision in Paychex v. Department of Taxation and Finance. Although the underlying dispute concerns whether certain reimbursement receipts should be included in New York's business apportionment factor, neither the trial court nor the Appellate Division reached that issue. Instead, both courts dismissed the case on procedural grounds. Jeremy and Chelsea walk through the distinction between the two courts' ripeness and exhaustion of administrative…
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