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New York ALJ finds receipts from electronic bill payment and presentment transactions constitute service receipts

An administrative law judge (ALJ) in the New York State Division of Tax Appeals determined that a taxpayer’s receipts from its electronic bill payment and presentment transactions constituted receipts derived from the performance of services, sourced to the location where the service was performed, in this case outside New York. In reaching its determination, the ALJ rejected efforts by the Division of Taxation to classify the receipts as other business receipts sourced to New York where, according to the Division, the receipts were earned.