Paychex’s Bid to Nix Tax Rules Was Properly Tossed, NY Argues

Paychex Inc. failed to exhaust its administrative remedies when challenging state income tax apportionment regulations, New York told a state appeals court in a brief urging it to affirm dismissal of the lawsuit.

The lawsuit was the first to challenge the tax department’s 2023 regulations, which were finalized after a nearly decade-long rulemaking process. The state passed its corporate tax reform law in 2014.

Paychex challenged the regulations before the New York Department of Taxation and Finance issued an assessment against the company, the state argued in a response brief filed Monday. Even now that the state has issued an ...