The Hayes decision, which is quoted in the 2022 CPA journal referenced by @Anonymous_, and which to my knowledge has never been challenged or overturned, states in very plain English:
"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."
Additionally, the oft-quoted New York tax memo TSB-M-06(5)I on the convenience rule, states in its very first paragraph:
"The memorandum addresses situations where a nonresident or part-year resident employee whose assigned or primary work location is in New York State performs services for an employer at that location and at a home office located outside of New York State."
https://www.tax.ny.gov/pdf/memos/income/m06_5i.pdf
I don't see any ambiguity here. The work income of a non-resident of New York who performs no services in New York State is not subject to New York income tax.
**Answers are correct to the best of my ability but do not constitute tax or legal advice.
