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Yes. Even if you are filing to get back mistaken withholdings from NY, you will need to file a nonresident return with zero income to do so. There is one caution, however. If you were a telecommuter working from home for a company based in New York, New York does treat you as working in New York, and does tax you. Their argument for doing so is called the "convenience of the employer" principle: it is for the employer's convenience, but not necessity that you are working from a remote location. (In other words, the work you are doing could in theory be done in the NY office instead of your house). If you are a telecommuter, the reporting is correct and you file a NY nonresident return on that income. Your state where you live would issue you a credit for the amount of tax you pay to NY on that income.
Otherwise, you would file a New York nonresident return, and on the allocation screens, you will state that none of the income was earned in New York, which should allow you to get a full refund of NY tax withheld. Having said this, retain proof because New York may want you to prove that you did not earn the income there.
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