Hotel Rehabber Asks NY Appeals Court to Nix $15 Million Tax Bill

Nov. 25, 2025, 9:09 PM UTC

New York’s tax agency didn’t provide any evidence to support its assessment of $15 million in corporation franchise taxes, a company that refurbishes luxury hotels told a state appeals court.

“The conclusion is inescapable that the department cannot provide a rational basis for any adjustment set forth in the notices,” Cushlin Ltd. told the New York Supreme Court, Appellate Division, Third Department, in its opening brief.

The New York State Department of Taxation and Finance estimated Cushlin’s tax liability after it failed to file tax returns for tax years 2002-2008. The company wants the appeals court to overturn a ...

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