General Electric Capital Corp. v. New York State Division of Tax Appeals

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• observing that because “[t]hird-party finance companies do not carry the burden of collecting sales taxes as a trustee of the State,” it was not arbitrary or capricious for Tax Commission to preclude third parties from pursuing refund claims pertaining to uncollectible debts
• refunds of sales taxes paid on receipts later determined to be uncollectible not available to third-party assignee
• no tax windfall to State where underlying sales transaction occurred separate and prior to purchase of accounts and nothing has changed status of transactions from taxable to untaxable
• “[W]here an agency adopts a regulation that is consistent with its enabling legislation and is not ‘so lacking in reason for its promulgation that it is essentially arbitrary,’ the rule has the force and effect of law.” (internal citations omitted)

Source: CourtListener parenthetical corpus (CC0).