New York Consolidated Laws

N.Y. Tax Law § 2000 (2026)

Statement of purpose

✓ text as retrieved May 2026 (this copy records no edition or section history)
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§ 2000. Statement of purpose. This article is enacted to establish an
independent division of tax appeals within the department of taxation
and finance which shall be responsible for providing the public with a
just system of resolving controversies with such department of taxation
and finance and to ensure that the elements of due process are present
with regard to such resolution of controversies. The division shall be
responsible for processing and reviewing petitions, providing hearings
as prescribed pursuant to this chapter or as a matter of right where the
right to a hearing is not specifically provided for, modified or denied
by another provision of this chapter, rendering determinations and
decisions and all other matters relating to the administration of the
administrative hearing process. The administrative hearing process is
the process commenced by the filing of a petition protesting a notice
issued by the commissioner of taxation and finance of a determination of
tax due, a tax deficiency, a denial of a refund or credit application, a
cancellation, revocation or suspension of a license, permit or
registration, a denial of an application for a license, permit or
registration or any other notice which gives a person the right to a
hearing under this chapter.
Notes of Decisions
Cited in 6 cases (3 in the last 5 years), 1990–2024 · leading case: New York State Soc'y of Enrolled Agents v. New York State Div. of Tax Appeals, 161 A.D.2d 1 (N.Y. App. Div. 2d Dep't 1990).
New York State Soc'y of Enrolled Agents v. New York State Div. of Tax Appeals, 161 A.D.2d 1 (N.Y. App. Div. 2d Dep't 1990). · cites it 2× “aw article 40 was enacted: "[t]o establish an independent division of tax appeals within the department of taxation and finance which shall be responsible for providing the public with a just system of resolving controversies with such department of taxation and finance and to…”
Matter of Dumpling Cove, LLC v. Comm'r of Taxation & Fin., 230 A.D.3d 927 (N.Y. App. Div. 3d Dep't 2024). · cites it 4× “Tax Law § 2000 provides that the Division is "responsible for providing the public with a just system of resolving controversies with [the Department] and to ensure that the elements of due process are present with regard to such resolution .”
Matter of Dumpling Cove, LLC v. Comm'r of Taxation & Fin., 230 A.D.3d 927 (N.Y. App. Div. 3d Dep't 2024). · cites it 4× “Tax Law § 2000 provides that the Division is "responsible for providing the public with a just system of resolving controversies with [the Department] and to ensure that the elements of due process are present with regard to such resolution .”
New York State Dep't of Taxation & Fin. v. Tax Appeals Tribunal, 151 Misc. 2d 326 (N.Y. Sup. Ct. 1991). “Section 2006 (5) of the Tax Law expressly empowers the Tribunal to dismiss a proceeding before it based upon a lack of subject matter jurisdiction.”
Matter of Beckerman v. New York State Dept. of Taxation & Fin., 232 A.D.3d 961 (N.Y. App. Div. 3d Dep't 2024). “and to ensure that the elements of due process are present with regard to such resolution" (Tax Law § 2000). Finally, to the extent that respondent's exhaustion argument is predicated on the availability of an administrative refund process, which would require petitioner to…”
Meyers v. Tax Appeals Tribunal, 201 A.D.2d 185 (N.Y. App. Div. 3d Dep't 1994). “Tax Law article 40, however, specifically provides for "hearings as prescribed pursuant to this chapter or as a matter of right where the right to a hearing is not specifically provided for, modified or denied” (Tax Law § 2000). Consistent with this policy, Tax Law § 2006 (4)…”
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