The convenience rule does not apply.
Per Hayes v. State Tax Commissioner, 401 N.Y.S. 2d 876, “A nonresident who works in another State but who performs no work in New York is not subject to New York State tax liability no matter for whose convenience or necessity he performs the work.”
To tax someone who did not work a single day in the state would be against the Due Process Clause in the constitution. One could argue that the convenience rule does as well, and it should be litigated at a federal level.
Essentially, if you worked 1 day or more in NY then they can use the convenience rule. Otherwise, their own non-resident guidance suggests the convenience rule does not apply.
