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which presumably becomes a disregarded entity. A final note. It is worth contrasting the holdings of these two opinions with the actual language of New York's estate tax law and its constitution. As noted above, the tax law (§ 960 of Article 26) says that estate tax applies to a non-resident decedent's tra
plies to a non-resident decedent's transfer of "real and tangible personal property having an actual situs in New York state." § 3 of Article XVI of New York's constitution, dealing with the taxation of intangible CONFIDENTIAL — PURSUANT TO FED. R. GRIM. P. 6(e) DB-SDNY-0 117711 CONFIDENTIAL SDNY_GM_0026
• A condominium is considered real property (unlike a cooperative apartment). • An Advisory Opinion from the New York State Department of Taxation and Finance is issued at the request of the taxpayer who requested advice about the New York state tax consequences of a proposed transaction or set of facts.
ions (but not those of NYS or its local governments) 21 Public employee 414(h) retirement contributions from your wage s tatements (see page 16) 22 New York's 529 college savings program distributions (see 23 Other (Form 1T-225, line 9) 24 Add lines 19 through 23 New York subtractions (see page 17) 2
xable year, state date terminated. (mmddiry) (Attach a statement showing disposition of business property.) 6. Has the Internal Revenue Service or the New York State Department of Taxation and Finance Increased or decreased any taxable Income (loss) reported in any tax period, or are you currently being audited?,„ YES X NO If 'YES', by whom? I
ons (but not those of NYS or its local governments) 21 Public employee 414(h) retirement contributions from your 4lage statements (sea Page 16) 22 New York's 529 college savings program distributions 23 Other (Form IT-225, line 9) 24 Add lines 19 through 23 New York subtractions (see page 17) 25 Taxabl
t taxable year, state date terminated. (mmddly) (Attach a statement showing disposition of business property.) Has the Internal Revenue Service or the New York State Department of Taxation and Finance Increased or decreased any taxable Income (loss) reported in any tax period, or are you currently being audited?. YES X NO If 'YES", by whom? In
obligations (but not those of NYS or its local governments) 21 Public employee 414(h) retirement contributions from yo s tatements (seepage 16) 22 New York's 529 college savings program distributions 23 Other (Form 1T-225, line 9) 24 Add lines 19 through 23 New York subtractions (see page 17) 25 Taxabl
t taxable year, state date terminated. (mmddly) (Attach a statement showing disposition of business property.) Has the Internal Revenue Service or the New York State Department of Taxation and Finance increased or decreased any taxable income (loss) reported in any tax period, or are you currently being audited?. YES X NO If 'YES", by whom? In
ury. I declare that I am the general partner or limited liability company manager of the taxpayer and that I have examned the information on its 2015 New York City electronically filed Unincorporated Business Tax return. including any accompanying schedules. attachments and statements or other report and to the
xable year, state date terminated. (mm-dd-w) (Attach a statement showing disposition of business property.) 5. Has the Internal Revenue Service or the New York State Department of Taxation and Finance increased or decreased any taxable income reported in any tax period, or are you currently being audited/ YES x NO If "YES", by whom? . . Int
Entities connected to both New York and the New York State Department of Taxation and Finance

United States
LOCATION
George W. Bush
PERSON
New York City
LOCATION
New York State
LOCATIONMaria Farmer
PERSON
NEW YORK NY
LOCATION
U.S. Treasury
ORGANIZATION
Joi Ito
PERSON
the Internal Revenue Service
ORGANIZATIONChang
PERSONUtilities
ORGANIZATION
York City
LOCATIONYonkers
LOCATION
FinCEN
ORGANIZATIONSpouse
ORGANIZATIONNew York State Sales Tax
ORGANIZATIONNY State
ORGANIZATIONthe New York State Tax Department
ORGANIZATIONDOTTED LINE & MAIL UPPER PORTION
ORGANIZATIONthe Commercial Rent Tax Return
ORGANIZATION