Webinar Transcript: “Hot Topics in NY Tax Audits and Enforcement”

Jonathan Shenkman

May 08, 2025

Webinar Transcript (5/8/2028): “Hot Topics in NY Tax Audits and Enforcement”

Host: Jonathan I. Shenkman, President & Chief Investment Officer of ParkBridge Wealth Management (Contact: jonathan@parkbridgewealth.com)

Presenter: Timothy P. Noonan, Partner - Tax Residency Practice Leader, Hodgson Russ LLP (Contact: TNoonan@hodgsonruss.com)

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Jonathan Shenkman: Hey? Good morning, and welcome to the Park Bridge Wealth Management Spring Webinar Series. This program is entitled Hot Topics in New York, tax audits and enforcement. As always. My name is Jonathan Shankman, and I'm the President, chief investment officer of Park Bridge wealth management. In that role I serve in a fiduciary capacity to help my clients achieve their financial objectives. The goal of my programs is to bring professionals together to help them better serve their clients, and

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Jonathan Shenkman: this is done by educating attendees on the latest topics in wealth planning, and by encouraging collaboration between a client's attorney, Cpa. And financial advisor, where appropriate my practice focus on working with high net worth families, businesses, and not for profits. I manage individual investment portfolios, trust accounts, corporate retirement plans and endowments to help my clients achieve their financial goals. In addition to the 20 or so events I run every year. I also do a fair amount of writing

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Jonathan Shenkman: on the topics of investing and financial planning. You can read my work in a variety of periodicals, including Barron's Cnbc. Forbes, Kiplinger, the Wall Street Journal, and Trust and Estates magazine to name just a few. You can see all my work on my website at parkbridgewealth.com forward slash articles by following me on social media, Jonathan on money. Additionally, you can check out my weekly, podcast

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Jonathan Shenkman: which is also called Jonathan on money, and you can listen on apple spotify, or wherever you get your podcast today, we're privileged to hear from Timothy Noonan, from Hodgson. Russ based in buffalo in New York City. By way of background, Tim is a partner and tax residency practice leader at his firm, where he focuses his practice in the State and local tax area. His work primarily involves New York State, New York City tax, litigation and controversy. Over the past 20 plus years

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Jonathan Shenkman: he has handled more than 2,000 personal income tax sales, tax corporate tax and other New York tax audits. Tim also has handled over 100 cases in New York's division of tax appeals. Tim has handled some of the most high Profile Residency cases in New York over the past decade, including a 2014 win in the guyed case one of the 1st New York Residency cases to ever reach New York's highest court. He's often quoted by the Media's outlet, including

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Jonathan Shenkman: Wall Street Journal, New York Times, and Forbes on Residency and other tax issues as the Noonan and Noonan notes a monthly column in tax notes. State Tim is a nationally recognized author and speaker on State tax issues. Today. Tim's going to be speaking on hot topics in New York tax audits and enforcement. And with that introduction I'll now turn the program over to Tim.

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Timothy Noonan: Alright, thanks, Jonathan. Hey, everybody! Good morning. Nice! Nice to be here again. It's a a annual event speaking with Jonathan, so I I very much appreciate the invite to this group. And you know.

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Timothy Noonan: I mean, this topic is, in some in one sense, somewhat of a niche topic like New York taxes like, what does that have to do with with me or my high net worth clients? But you know, in particularly around the State of New York. This has been a big issue, because New York's audit and enforcement efforts have for years been focused.

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Timothy Noonan: well, sort of on everybody, but in in every company. New York is very aggressive, but in particular in the high net worth space in, you know, people moving from New York to Florida people who work in Connecticut or live in Connecticut, but work in New York. In other words, a real focus on auditing individuals. For their own personal taxes. And that ends up obviously being a significant issue for high net worth individuals, their advisors, because issues are popping up all the time. So

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Timothy Noonan: it is a a a big topic in this space. So just want to spend some time, you know, this morning giving you a sense of what's going on. What are the hot topics in New York? What are some of the the big cases and issues? To give you a sense of things that you know you and your clients should should be looking out for. So

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Timothy Noonan: with that intro, there's actually, we just got some really interesting data. From the tax department. We did a freedom of information law request, as sometimes we do, just to sort of you know.

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Timothy Noonan: I mean government's great. They have to give you information if you ask for it. So we asked for information about like, Hey, you know what's going on like from an audit perspective. How many audits are you doing? How many dollars are you collecting? We like to have a sense of that for a couple of reasons both. So we can properly advise our clients. And you know, as my business is, you know, handling and defending a lot of these cases, interesting to see what's going on. And we had a sense that things were changing a bit, not so much in the the

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Timothy Noonan: flow of work that I was seeing, but just in the the number of auditors in particular that were out there. And if you look at the the data here on this 1st set of slides.

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Timothy Noonan: You see a drop in auditors who do sort of the regular auditing you know, for the tax department dropping, you know, from 360 or so in 2,000

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Timothy Noonan: down to under 250 in 2024. We certainly knew that was going on. That was in part actually due to the Internal Revenue service. Remember, a number of years ago, President Biden allocated. I don't know. 87 billion dollars, or something to like beef up the irs. And they did. And they hired a lot of people.

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Timothy Noonan: Funny story, or maybe not so funny like, that's changed right? So lots of those tax department, you know, New York Tax Department auditors that got hired away to work for the Irs lost their jobs in the past 6 months or so a lot of them are coming back, but you see a drop in auditors, and you know, you see a sort of a drop in audits in the next slide we track. They're both like Residency audits again. We'll talk about that in a minute.

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Timothy Noonan: That's probably the biggest topic in the high net worth space in terms of how how to deal with State Residency. in in New York and so we see with the drop of auditors, we see a drop in audits not really surprising. I mean the the number, the sort of sheer number of drop in audits actually was was surprising to us to see that

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Timothy Noonan: that could be a blip but we do have a couple of years that they did less than a thousand Residency audits, which is again a bit surprising. There was a big blip, you see that in 2022 I don't know what they were doing there that you know, just in regular audits they went way up. But the that that seems to be trending, obviously trending way down again. So you know good news potentially that sort of audit enforcement

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Timothy Noonan: appears to have gone down the next set, although, is interesting, because

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Timothy Noonan: and again, the data here might be a year lag like. If an audit is opened in 2022, it probably doesn't get closed until 2023, etc. So on one side we see number of audits close, with no changes. That's no changes, is very good news in my world. That's a win. So no changes are great, and the flow of those seem to sort of go with the audits, though the percentages maybe seem to be the same. But then, on the next side. You have the total number of audits where they didn't agree.

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Timothy Noonan: and they're still, you know, that doesn't really flow as much with the trend of cases there still is a similar amount of disagreed cases, even when you have 10,000 audits versus 2 or 3,000 audits, which is kind of interesting. So they're still, they're still sort of fighting. Maybe the same amount of cases at the appeals level. They're just opening more cases. And maybe that just means they're kind of inefficient. They're opening lots of cases where they're just saying.

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Timothy Noonan: Well, I guess you know. Well, or maybe they're getting better, because that could mean. There's agreed cases here where they assess a tax and it gets paid that wouldn't be on neither. Chart here, right? This is just the difference between total total victories for taxpayers, and in cases that end up disagreed. But

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Timothy Noonan: so you see that, and then just dollar wise this sort of tracks with the number of audits. It's like the amount of dollars they collect. But

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Timothy Noonan: I mean, this is big business in New York State, you know, they collected, or they at least they assessed over a billion dollars in in disagreed cases. For instance, in 2023. Obviously, it's a big number. They collected 500 million in in 2023. So again, this is, you know, for New York State. It has been a big business. It does sort of

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Timothy Noonan: makes me question what's going on back there on the 1st slide, where the number of audits auditors are dropping, the number of audits are dropping. I don't. I don't think that's by design. I don't think they want that but

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Timothy Noonan: they lose. It's, you know. It's the government. So they lose people. It's sort of hard to quickly fill people. They, you know, they can't just say, Oh, we're going to pay people a lot more to get them in like a private business would be when they have like a war for talent. Can't really do that at the State. It's a little more, you know, Lockstep and it, you know, it takes a lot of time and energy and legislation, or whatever to

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Timothy Noonan: change compensation. There's union issues. So they just move a lot slower. So I

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Timothy Noonan: I don't necessarily think that

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Timothy Noonan: The enforcement is going to continue to drop. As it is.

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Timothy Noonan: If it does, I'll be talking about something different next year. I'm just kidding, but you know that, you know it is an interesting trend that I would say in 26 years of doing this. I sort of haven't seen that but again, I think it's it's the the loss of audit staff that I that they're shoring up now, that could be a a direct cause of that. Okay, so talk it. Let's get into a few substantive topics today. So

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Timothy Noonan: Residency audits like I said, this is a big topic in New York State kind of for an obvious reason. The highest New York State personal income tax rate is now 10.9%. If you are fortunate enough to live in New York City, add another 3.8% on top of that.

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Timothy Noonan: like 14 or so percent in state and city or state and local personal income tax there, that's the highest in the country. When you, when you think about the combined rate. And since 2018, as I'm sure many of you know.

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Timothy Noonan: essentially you're not able to deduct your state and local taxes. The so-called famous salt deduction. That went away or was capped at $10,000 a year in 2018.

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Timothy Noonan: So that made the sort of sting of 14% state tax rate. But that's before you pay a dollar in Federal taxes. Right? That's

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Timothy Noonan: or I should say that's after you pay many dollars in Federal taxes you still have to pay up to 14% New York taxes. That's heavy duty. And when you can't deduct that, that's even worse. So that means people think

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Timothy Noonan: I think I want to get the heck out of here right 5 years ago. Covid hit Jonathan still did a webinar. I remember it very well. In early May 2020. But I you know, not like I was some genius, but I predicted at that time, hey? I think a lot of people are gonna move from New York. Sure enough, they did. Tons and tons and thousands and thousands and tens of thousands of people left.

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Timothy Noonan: and and many of them became my clients because they needed help leaving. And now they're all getting audited. So but

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Timothy Noonan: but Residency becomes such a big thing because the tax rate so high, so people are trying to avoid that totally legally by moving or by spending less time in New York and New York doesn't really like that. So they're looking at those folks

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Timothy Noonan: incidentally, just a side note on the salt deduction. That's sort of in the news all the time. Now, right will the Feds change that? Will they get rid of the cap and start to allow taxpayers in high tax states like New York and California, to start to begin to be able to deduct their State taxes again.

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Timothy Noonan: I mean, the short answer is, I mean, I don't know. I I probably know as much as you and and Google knows, or or AI. But I don't think it's gonna happen like in terms of probably what will happen is they'll raise the cap from $10,000 to $20,000, which, if you're a New York taxpayer, you're paying $20,000 in tax, like

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Timothy Noonan: by January 14, th or something. Right? So they'll they'll raise the cap a little bit, or maybe they'll maybe raise it even higher, but they'll limit it to taxpayers making you know, under $400,000 or or something like that. So I think that the cap itself that impacts all of our clients

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Timothy Noonan: is, for all intents and purposes likely to stay. It's really just too expensive at this point for the Feds to to turn that off.

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Timothy Noonan: There is, of course, as many of you know, sort of a fail safe to that. There's many states, pretty much all States. New York has a Pt, a pass serenity tax that's designed to soften the pain or really get around the pain of the salt cap. So those are still alive and kicking, and great to avoid the pain of the salt cap. But those are out there. But in any case, you know the salt cap, high taxes.

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Timothy Noonan: bad weather, whatever. People are moving, people move, people are moving. It's it's an issue. I know. Here the 300 auditors. Actually.

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Timothy Noonan: I should revise that slide. Because now it's 240 at least, based on the the foil data we just got a couple of weeks ago. So auditors are dropping. So what does that mean? Like in terms of an audit? There's a big question I get all the time people call me, hey? I want to move to Florida.

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Timothy Noonan: Am I going to get audited? And the the sort of math isn't really all that complicated right? The more you make, the more likely it is they're going to audit you. They're not, you know. They're they're they're business people, so to speak. They're not gonna

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Timothy Noonan: chase after taxpayers who make $100,000 a year, because the most amount of tax they could get on an audit like that is like 5 grand. They're just not going to do it. They're going to chase after the bigger dollars. So the higher your income is, the more likely it's you're going to get audited these days. I think if your income is under a million dollars, you're probably not going to get audited. I'm not talking wealth or anything. I'm talking annual income

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Timothy Noonan: under a million bucks. I just don't see them chasing after those audits anymore. They we've seen it. They don't have the staff to do so. They're focusing on the larger dollars.

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Timothy Noonan: maybe that's even growing now, with more people moving right and less people to audit.

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Timothy Noonan: Could that be 3,000,004 or 5 million. Maybe I still see audits in that realm, for sure. But I think you know, whereas I probably would have said Pre covid over a million bucks or so. Your likelihood of audit and sort of one of these Residency cases where someone's moving from one state to another is pretty high, maybe close to 100. I can't say that anymore. If your income is over 10 million dollars.

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Timothy Noonan: I think it's probably still very close to a hundred percent. That there's going to be an audit again. They still they still do a lot of these audits. But again, I'll

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Timothy Noonan: have more data and more intel on that maybe in a year, as we see what the if they've short up their their audit group because I mean they can't audit everybody and there's only so many, you know, so much time in the day. So I think the audit likelihood could go down. Maybe that means people start to be more aggressive. Like, if you know you're gonna get audited. And someone calls me and says, Oh, here here are my facts. Here's what I want to do.

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Timothy Noonan: And I say, you're gonna lose. Then we know we're gonna get audited. Maybe we don't do it. But if someone's like, well, there's a 30% chance I'm gonna get audited. What the heck? Maybe I'll give it a shot. And that's but that's key, right? Because in in these cases, again, when we're thinking about, you have a client who's thinking about making a move.

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Timothy Noonan: You know, the the burden of proof issue here is is so large there's no close calls. You have to prove by clear and convincing evidence that you've changed in this case, if you're changing residency, that you've changed your residency from

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Timothy Noonan: New York, to the new State, to Florida. There's 2 tests in New York. One is the test everyone knows about. Oh, I'm going to meet my days. I'm going to spend more than 6 months out of New York. That's fine. There is one rule that says you can't spend more than 6 months in New York, or 1 83 days. If you do that game over, you lose. But even if you're under 1 83 days, you can still be taxed as a New York resident. If the tax department determines that your domicile or your primary home

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Timothy Noonan: hasn't changed, that it's still in New York that ends up being a balancing test between your ties in New York or your ties in Florida. And that's where I say, a close call

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Timothy Noonan: close call. We're gonna lose that case because they're gonna say it's not clear and convincing. Clear and convincing is, you know, a lot heavier weighted towards Florida and away from New York, and oftentimes your time patterns

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Timothy Noonan: are the biggest or the best piece of evidence there, and if you spend about the same amount of time in New York and Florida. They're going to say that's a close call, and you know that's going to favor the Government.

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Timothy Noonan: That wider that gap in days gets the better. The case is going to be. So as we're advising people on these moves like this, we are focused a lot on time patterns and how much time people are spending in different places with that, of course, becomes the question of how do we prove it? How do we prove our days? And you know. Maybe 20 years ago, when I was doing these things. I don't think we had webinars 20 years ago, but, like, you know, it was a little tougher, right.

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Timothy Noonan: easy pass credit card records, people using cash a lot like, you know, we had to prove in these cases the burden proofs on us. We have to prove where we were every day of the year, and that that actually is tough was tough years ago.

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Timothy Noonan: Now we got cell phones. We're all carrying around these cell phones. They're pinging towers here and there. Most of the carriers will give us that data. It's a lot easier to see where people are. There's apps people have on their phones now. You know, most of my clients coming to me are are aware of them. They're using. They're using apps to track themselves. So that's become a little bit easier but proving where you are in these cases is is is is, you know, again, a a very big deal. So

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Timothy Noonan: that's what we got on the on the audit side. The last thing I'll say is, like, you know, these cases aren't all or nothing. They're not binary, it's not win or lose. Oftentimes, when you have these residency cases that are kind of facts and circumstances, settlement is definitely an option, and they will settle cases.

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Timothy Noonan: Speaking of cases, the other big update. Really, since Covid has been this whole convenience rule thing, what's the convenience rule? Well, the convenience rule is basically New York's telecommuting rule.

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Timothy Noonan: If I'm not a resident of New York. But I'm working in New York and I'm getting salary, wages, bonuses, compensation like that. I have to pay tax to New York based on the amount of days I work in New York pretty easy math. How many days did I work in New York? Okay? Worked. You know, 60% of my days. I gotta pay tax on 60% of my compensation. Again. If I'm not a resident, if I'm a resident, I pay tax and everything that's easy. Well, New York has a rule that, and has had a rule for decades.

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Timothy Noonan: If you're telecommuting from home to your New York office and you're doing so for your convenience. New York's rule is, that's a New York Day. For purposes of doing that math. You've got to treat that as a New York day that's called the convenience rule, and convenience, historically, has been really defined very broadly. The only thing that wasn't a convenience day in in the tax department's mind was, if your employer told you to go like oh, go work, you know, at our client site

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Timothy Noonan: in Connecticut or go work in New Jersey like, if you're just working from home. The New York's rule was, that's gonna be a New York day, even if you're working from home in New Jersey or Connecticut or Florida, or wherever well, and that was the rule for decades, and there's been cases here and there on it, but it it sort of quieted down until something called Covid, when everyone started working at home again

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Timothy Noonan: in New York, doubled down on this telecommuting role

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Timothy Noonan: and said, basically, we don't care that

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Timothy Noonan: You work from home for most of 2020 and 2021 heck! We don't even care that your office was closed and you had nowhere to go. We're still going to apply our convenience rule. Well, that's that's under attack now, or you know, the taxpayers are fighting that we have a number of cases still kicking around on this issue. There's a case coming out probably in a couple of weeks.

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Timothy Noonan: A Professor Ed Zelensky, who had a case with New York 20 years ago, where he fought the convenience, rule, and loss has revived his claim. Now, post Covid arguing in essence. He's arguing a number of things, but I think the the one issue that I think we're all watching Super closely, because it matters for a lot of 2020 and 2021 cases is whether or not this telecommuting rule can apply.

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Timothy Noonan: even if the employer's office was closed, which again, for many employees, they didn't have anywhere to work in 2020 and 2021. So the idea that those days worked at home could be convenience days is kind of silly. So

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Timothy Noonan: we're expecting a ruling from New York's tax appeals tribunal in a couple of weeks on that and when it comes out I'm sure it'll be all over the news. It'll be sort of the biggest case involving sort of Covid tax enforcement in New York.

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Timothy Noonan: That's really come out. So that'll be interesting to to see

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Timothy Noonan: couple of other things. Corporate tax reform which you know, you might say. Well, you know, we're really here to talk about individuals and high net worth tax planning and things like that. What would I care about corporate tax reform? Well, one of the things that comes up a lot is pass through taxation. Taxpayers who individual taxpayers who are shareholders of S corporations.

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Timothy Noonan: compute their tax based on the corporate rules. So corporate rules do become relevant for lots of individuals. And just interestingly, like, you know, the State changed a lot of its corporate tax rules back in 2015, made a lot of changes in the way corporations were taxed pretty much designed in part to bring in more revenue from out of State businesses and out of State companies. But

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Timothy Noonan: it then took the tax department 9 years to issue tax regulations which were extremely substantive, like thousands and thousands of pages of substantive rules enforcing the statutes that came on the books in 2015. And for some of these obviously taxpayers didn't like the results of the regulations. So they've started to challenge them in one case, just a couple of cases that came out in the past

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Timothy Noonan: couple months. Paycheck sued New York, arguing that in a special apportionment rule that was put in place in the regulations was both inconsistent with the statute, and it shouldn't be applied, you know, retroactively back to 2015, anyway, which is what the tax department tried to do with all of its regulations that it passed in or issued in December of 2023.

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Timothy Noonan: In another case, one part of the regulations took sort of a swipe at the nexus provisions in public 2 72, which essentially protects out of State businesses from income taxes if they have no physical presence in New York outside of sales activities. In any case.

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Timothy Noonan: taxpayers in both these cases challenged

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Timothy Noonan: both the viability of these, the sort of the the substance of these rules, but also the idea that what the heck you can't go back 10 years on these rules, and you know we're one for one like. In one case taxpayer lost. The the court said, No, no, it's fine

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Timothy Noonan: we can. They can enforce these rules retroactively. In another case, the 86, 2, 72 case just came out like a week ago. The court said, no.

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Timothy Noonan: 9 years is ridiculous. You can't, you can't. You can apply it prospectively. New York, if you want to do that.

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Timothy Noonan: but you can't apply it retroactively. And you know that's a bit of

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Timothy Noonan: sometimes courts and judges come out differently. It could be something in the facts. In the paychecks case there was more of a history of back and forth with the taxpayer and the government about the change. It was kind of like, Hey, you guys knew this was coming kind of thing, so that could be a difference in these retroactive cases. But certainly that's something that's out there as well.

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Timothy Noonan: Okay. So New York City taxes. So New York City has its own sort of separate tax enforcement regime. And this this regime actually relates to New York City's tax called the Unincorporated business tax.

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Timothy Noonan: which again, is a tax on businesses per se. But it's on flow through businesses, partnerships, Llcs sole proprietorships, and New York City has been very aggressive in forcing this 4% tax

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Timothy Noonan: against you know, providers really provide a lot of providers of services in New York City. Your accounting firm, your law firm, your wealth management firm, your hedge fund, your Private Equity Management company like these businesses doing business in New York City. Their owners have to pay taxes right based on the personal income taxes that 14% potential tax I mentioned.

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Timothy Noonan: But the entity also has a 4% tax just on the entity's business income. In New York City has been extremely aggressive in going after taxpayers

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Timothy Noonan: on, on, particularly in the financial services area. Again, hedge funds hedge fund management companies, private equity firms.

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Timothy Noonan: you know, firms that have, you know, built homes for themselves in New York City. And you know the city is like, thank you for doing that. Now we're going to audit you right? So lots of enforcement. This is another reason. We saw lots of you know, hedge funds and such move to Florida in and around Covid to avoid situations like this, where, in addition to the owners having to pay a 14% tax, there's a 4%

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Timothy Noonan: entity tax on top of that.

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Timothy Noonan: But again, the city is focusing on a couple of different areas. One of the big areas is apportionment. So you know, if you're a business in New York City. You have to pay this 4% tax, but if you're a service provider

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Timothy Noonan: you might not have to pay it on 100%. The allocation or the apportionment rule is based on where you're performing your services. So the percentage of services you are performing in New York City will dictate how much tax you have to pay.

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Timothy Noonan: So if if you're only performing half of your services in New York City, then you're only paying half the tax that you would pay if you were performing all your services in New York City. Well, again, Covid made an issue of that because people were like, Well, wait a minute. I didn't. All of our people in 2020 and 2021 they they sort of went went home, and they work from home for a year or so.

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Timothy Noonan: and many of those folks didn't have homes in New York City.

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Timothy Noonan: Well, there's no convenience rule right? There's no telecommuting rule that I talked about a couple of minutes ago. For for this ubt tax. It's really where people were doing the work. So if you were not doing the work in New York City

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Timothy Noonan: you could lever down your apportionment percentage. So that's been something that a lot of taxpayers did

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Timothy Noonan: to lower their New York City taxes. Now, the city is auditing lots of those cases. And interestingly, they're not saying that taxpayers can't do that. They're allowing taxpayers

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Timothy Noonan: to lever down their apportionment. If indeed, services were provided outside New York City. But you got to prove the services were provided outside New York City. It becomes an issue of proof similar to kind of like the day count thing I was mentioning in Residency cases. But it's a similar idea. If you have a bunch of service providers.

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Timothy Noonan: You're providing, you know, investment management services, and you have portfolio managers and folks working from different places. You got to figure out where they were. Where are they working? They're working from home outside the city. That's great. We can treat that as non New York City services. But we got to be able to prove it so.

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Timothy Noonan: But again, the city isn't saying. I mean, I had one case where the city said

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Timothy Noonan: the auditor said, well, 2020 was weird year. So we're gonna use 2019. And and we're not gonna allow them to sort of get the benefit of all the work from home and whatnot in 20 20, and they should have tax bill to my client based on that. But we took it to the appeals level and the appeals people are like, no, it's not the rule you can definitely look to where people were, but prove it. So we had to still prove it.

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Timothy Noonan: But the concept that, you know. Somehow the normal rules wouldn't apply to 2020 or 2021 has been ditched so I wouldn't worry about that. The last thing, I'll say, and this is this issue somewhat in New York State, too. But in New York City especially

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Timothy Noonan: man, these audits are taking forever. The city like the State has lost a lot of audit staff. So the cases are really old. They're big cases. There's lots of issues. There's not enough auditors to do them. Cases are going on and on. And the other thing that's happening is at both the State and city level. There's like a tax court system.

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Timothy Noonan: So if you don't like the result, you get in your audit, you can appeal it. There's administrative law judge who's judges who hear cases. There's sort of like an appellate review body that looks at those cases all within sort of the tax department structure. Again, it's basically like New York State or New York City's version of of tax court.

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Timothy Noonan: So they have these tax courts.

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Timothy Noonan: but they're kind of dysfunctional. The city tax court is especially dysfunctional right now. There's no judges, like all the judges, are gone. So we have cases sitting there, and it's like there's nothing to do. We're all sitting waiting for a judge to even sort of get hired. There's no judges. So that's kind of a problem. I actually just wrote a piece about that in tax notes in my monthly column. Just about kind of that dysfunction, and how there's no judges. So that's a problem. You know you don't.

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Timothy Noonan: If you don't have a judge to adjudicate your matter. It's kind of tough to get a good result. So that's been a problem, too, in the in the tax enforcement realm in New York city.

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Timothy Noonan: Okay? So got through the topic. All my contact information is there. If you guys have questions, feel free anytime to call me shoot me an email, happy to take questions about this or any other any other New York tax or other State tax matters. And so I got Jonathan over back to you.

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Jonathan Shenkman: Great. Thank you so much, Tim. If anyone has any specific questions, new business opportunities, or any other issues I'd like to discuss, please feel free to reach out directly to Tim or myself where appropriate. And I'll also be sure to include his contact information in the follow up email to this program. As I mentioned at the onset, the goal of these programs stay up to date on timely wealth management, related topics.

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Jonathan Shenkman: and to collaborate where appropriate. And I think we could all agree that the clients who are best prepared are the ones who are served by a team of knowledgeable advisors. 3 more quick items before I let you go first.st My next webinar is Tuesday, May 20, th at 8 30 Am. Featuring John Kiley of Mcdermott, Will and Emory, based in New York City who's going to be speaking on the topic of the Irs issues final regulations on gifts and bequests, for from covered expatriates, and I'll be sure to send out invitation to this program

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Jonathan Shenkman: in the coming days. In the meantime, I'd love to continue to grow this webinar community. So if you have a friend, colleague, or client who like to be notified of my upcoming webinars. They can email me with the word webinar on the subject line. I'll add them to my webinar distribution list. My email is Jonathan at parkbridgewealth.com. Second, you can follow all my work on X and Instagram at Jonathan on money, and by connecting with me on Linkedin, you could also listen to my weekly podcast called Jonathan on money, which is available on apple spotify, or

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Jonathan Shenkman: wherever you get your podcasts. And you can watch my practical planning videos, which I post several times a week by following me on Youtube at Jonathan money as well. And 3, rd please take 30 seconds to fill my survey at the end of this program. It helps me improve my webinars and provide timely and interesting content to attendees. I thank you in advance for that. And with that this concludes today's session.

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Jonathan Shenkman: Please stay safe and healthy and have a wonderful day. Everybody.