State tax filing

@DanielV01 NYS Regulation Section 132.18(a) is the current State regulation, it's not old.  The reason there hasn't been a case since the Matter of Hayes, is because it was binding precedent to the State. In order to overturn it, the State would need strong grounds to do so. No such grounds have existed in the past 40+ years.

You make it sound like I am suggesting the convenience rule isn't applicable in most cases, I never said that. The convenience rule applies for employees who perform some of their services in New York, and some of their services for their employer out of State, for their convenience. It does not apply to employees who perform ALL of their services out of the State. There is a very important distinction that you are failing to recognize between none and some.

The case you cited doesn't align with the facts given by @unknownzack.  Zelinsky was a NY professor that worked in New York, and did some work at home in Connecticut. Where in the post, did @unknownzack suggest he performed some services in New York during the 2021 tax year? He has a New York employer, that is not sufficient to subject his wages to allocation under NYS Reg. Sec. 132.18(a).  He has to at least work one day in New York for the convenience rule to potentially apply. 

If he worked lets say 20 days in New York in 2021, then yes, he would be subject to the convenience rule unless he could show that his home office met the bonafide home office test or he worked from another bonafide office location of his employer in Florida. That is not the topic of this particular discussion.

And no, with all due respect, this isn't a debate. For those that work zero days in New York in any given calendar year, it is a clear-cut topic, no NYS taxes on their wage income. If you want to do a bit of due diligence, email one of the contributors to the article you sent to me, and ask them. I have 100% confidence any one of them will tell you the same thing.