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Constitutional Law Keyed to Choper
Lunding v. New York Tax Appeals Tribunal
Citation:
522 U.S. 287 (1998)Facts
In 1990, petitioners Christopher and Barbara Lunding were Connecticut residents. Christopher earned substantial income from practicing law in New York and paid alimony to his former spouse from a previous marriage. When filing their New York nonresident income tax return, the Lundings claimed a pro rata deduction for alimony paid, calculating that approximately 48% of Christopher’s business income was attributable to New York. The New York Department of Taxation and Finance denied the deduction based on N.Y. Tax Law § 631(b)(6), which specifically prohibited nonresidents from deducting alimony payments from their New York source income. This resulted in an additional tax assessment of $3,724 plus interest. New York’s tax system for nonresidents required calculating tax as if they were residents (including all income and deductions), then applying an apportionment percentage based on the ratio of New York income to total income, but specifically disallowed alimony deductions for nonresidents in the numerator of this calculation.
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