State Tax Day - Current, S.6, New York City—Miscellaneous Tax: Insurance Agent Was Independent Contractor Subject to Unincorporated Business Tax, (Sep 8, 2026)
The New York City Tax Appeals Tribunal affirmed an administrative law judge determination holding that an agent for an insurance company was an independent contractor whose income was subject to the unincorporated business tax. The agent's claim that he was an employee of the company was rejected. The record did not establish that the company possessed or exercised sufficient control over the means and methods of the agent's work to create an employer-employee relationship.
Friedman, New York City Tax Appeals Tribunal, TAT(E)03-21(UB), TAT(E)03-22(UB), TAT(E)03-23(UB), August 26, 2026, ¶600-944
Other References:
Explanations at ¶519-110