State and Local Taxes

Robinson+Cole was one of the earliest law firms to participate in the area of state and local taxation, with an established practice that dates back to the early 1980s. Our state tax practice involves the following:

  • representing businesses before state taxing authorities
  • conducting tax litigation
  • advising clients regarding state tax compliance and business structuring
  • designing for our clients favorable tax legislation, including tax incentives
  • assisting businesses in securing existing tax and financial incentives

Our tax lawyers are recognized leaders in the field. They have secured numerous rulings and other administrative guidance for taxpayers on uncertain tax issues and have worked to shape tax regulations and other guidance in a manner favorable to the interests of our clients. In Connecticut, they have successfully resolved hundreds of state and local tax disputes at the administrative agency level, in court-supervised mediation, in trials of cases, and in appeals to the Connecticut Appellate and Supreme Courts. Members of our Tax Group author annual publications for the ABA and the Connecticut Bar Journal and regularly publish in nationally distributed state tax publications. Our lawyers are sought after as speakers by numerous organizations, including COST, state business leagues, and CPA societies, and chair subcommittees of the ABA Tax Section's SALT Committee. Our group includes past chairs of the Connecticut Bar Association's Tax Section. In addition, a member of our State Tax Group served for more than seven years as the legal division director of the Connecticut Department of Revenue Services.

Our State Tax Group regularly represents all types of business and individual taxpayers in matters involving state franchise, income, sales and use, property, and a wide variety of special industry taxes. Our lawyers handle state and local tax audits, administrative appeals, and tax appeals to the courts. An important part of our state and local tax practice involves the negotiation of tax incentives for companies considering location or expansion of activities in a state. This includes negotiating administrative rulings involving application of the tax laws to a company moving to the state, drafting and enacting favorable tax legislation targeted to specific companies or industries, assisting in the structuring of the sale of state tax credits, and negotiating tax and other financial incentives with state agencies charged with an economic development mission.

    • Experience
      • State Tax Representation

      • Successfully represented high-income taxpayers in residence/domicile disputes with Connecticut DRS.
      • Representation of American Honda in Connecticut litigation regarding the inclusion of registration fees in sales tax gross receipts.
      • Counseled taxpayer in Foodways National v. Crystal re treatment of public warehouse space for apportionment purposes.
      • Represented taxpayer in Steelcase, Inc. v. Crystal re sales tax on drop shipments.
      • Represented taxpayer in Toys 'R' Us v. Gavin and numerous other appeals regarding special purpose holding companies.
      • Collaborated with Connecticut Department of Revenue Services on legislation clarifying application of corporate tax to corporate partners.
      • Represented taxpayer in securing favorable sales and use tax treatment of sale-leaseback transactions in Connecticut and Massachusetts.
      • Represented corporate partners in litigation relating to passthrough of corporate tax credits.
      • Provided an opinion regarding the application of Connecticut's sales and use tax exemption for the purchase of large aircraft.
      • Represented corporation in settlement of dispute regarding allocation of goodwill following acquisition.
      • Assisted resident general contractors and nonresident contractors to comply with Connecticut law.
      • Advised clients regarding residence of trusts, taxability of trusts, and reformation of foreign trusts.
      • Advised clients regarding discharge of indebtedness issues.
      • Assisted estate in resolving erroneous probate and tax filings.
      • Represented client in State tax audit related to Son-of-Boss-type transaction.
      • Successfully represented several taxpayers in multistate nexus and voluntary disclosure matters.
      • Has proposed and secured approval of innovative approaches to tax compliance for nonresident contractors.
      • Successfully resolved Connecticut audits of purchases of high-value art and yachts.
      • Represented taxpayer in appeal of Connecticut-listed transaction assessment.
      • Represented taxpayers in domicile and residency audits.
      • Represented a generator of electricity in connection with a Connecticut corporation business tax audit and administrative appeal relating to application of fixed capital investment credits and successful settlement of the issues presented.
      • Drafted new insurance reinvestment fund tax legislation in Connecticut and represented a group of venture capital partnerships in establishing an insurance reinvestment fund approved by the Connecticut Department of Economic and Community Development to channel investments by insurance companies into start-up or emerging businesses in Connecticut. These types of funds exist in some other states and are commonly referred to as Capco Funds.
      • Tax

      • Regularly represents clients, as lead counsel, in personal and real property tax appeals for commercial taxpayers against Connecticut municipalities. Consistent record of obtaining favorable resolutions for clients involving valuation disputes between the taxpayer and the municipality concerning, among other things, Section 8 CHFA valuation issues, high-tech equipment valuation, and special use properties.

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    • News
      • November 28, 2017

        Ryan Leichsenring Presents at UCONN Income Tax School

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      • October 11, 2017

        Ryan Leichsenring Speaks on Tax Credit and Incentives at CFO Knowledge Network Event

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      • December 6, 2016

        Ryan Leichsenring Speaks on Virtual Economy at State Tax 360° Conference

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      • July 17, 2014

        Felicia Hoeniger Presents at Conferences on Connecticut Tax Issues

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      • December 19, 2013

        Felicia Hoeniger Speaks on Current Tax Issues

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      • November 15, 2013

        Hartford Symphony Orchestra Elects Bruce B. Barth to Board of Directors

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      • November 1, 2013

        Robinson & Cole Receives 34 First-Tier Metropolitan Rankings and Three National Rankings in U.S. News – Best Lawyers Survey

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      • October 21, 2013

        Super Lawyers® Names 61 Robinson & Cole Attorneys to 2013 List

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      • August 22, 2013

        Robinson & Cole Announces Annual Pro Bono, Mentor, and Community Service Awards

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      • August 16, 2013

        Robinson & Cole Receives Top Listing in Connecticut Attorney Count in Best Lawyers National Peer Review Survey

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      • August 2, 2013

        Hartford Lawyers Co-author Article on Connecticut Tax Law

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      • July 24, 2013

        Christine Bromberg Elected Vice-Chair of Junior Achievement of Southwest New England’s Board of Directors

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      • July 9, 2013

        Scott Sebastian Selected for Lawyers of Color's 2013 Hot List

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      • July 1, 2013

        Robinson & Cole Lawyers Speak at Connecticut Tax Conference

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      • June 18, 2013

        Susan E. Roberts Elevated to Counsel at Robinson & Cole LLP

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      • June 11, 2013

        Susan Roberts Speaks at NBI Seminar

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      • April 30, 2013

        Hartford Tax Lawyer Participates in UConn School of Law Panel

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      • April 18, 2013

        Scott Sebastian Elected Commissioner in West Hartford

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      • February 22, 2013

        Susan Roberts Presents at Lorman Seminar

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      • January 4, 2013

        The Wall Street Journal Quotes Felicia Hoeniger

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      • December 24, 2012

        Christine E. Bromberg Speaks at Connecticut Society of Certified Public Accountants’ Annual Tax 360 Conference

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      • December 21, 2012

        Felicia Hoeniger Addresses Accountants at University of Connecticut Income Tax School

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      • December 10, 2012

        Scott Sebastian Continues Leadership Role with Connecticut Asian Pacific American Bar Association

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      • November 20, 2012

        Tax Attorneys Taking on Leadership Roles with Connecticut Bar Association Tax Section Executive Committee

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      • November 7, 2012

        Robinson & Cole Receives 32 First-Tier Metropolitan Rankings and Four National Rankings in U.S.News - Best Lawyers Survey

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      • November 1, 2012

        Scott Sebastian Part of Faculty for Sales and Use Tax Seminar

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      • October 22, 2012

        Super Lawyers® Names 49 Robinson & Cole Attorneys to 2012 List and Recognizes 26 as Rising Stars

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      • August 28, 2012

        Robinson & Cole Receives Top Listing in Connecticut Attorney Count in Best Lawyers National Peer Review Survey

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      • August 14, 2012

        Hartford’s Camp Courant Selects Tax Attorney Scott Sebastian to Serve on its Board of Directors

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      • June 8, 2012

        Tax Attorney’s Article Discusses State Tax Residency and Domicile Issues

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      • May 16, 2012

        Felicia Hoeniger Presents to New York Tax Study Group

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      • December 23, 2011

        Attorneys Offer Advice on Connecticut Taxes for Upcoming Tax Season

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      • December 5, 2011

        Robinson & Cole Attorneys Participate in the Connecticut Society of CPAs’ Annual Tax Conference

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      • October 6, 2011

        Tax Lawyer Discusses How States are Limiting Sales and Use Tax Refunds

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      • September 22, 2011

        Tax Attorney Joins Robinson & Cole’s New York Deal Team

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      • September 6, 2011

        Tax Attorney Offers Advice to Businesses at Sales and Use Tax Seminar

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      • August 31, 2011

        Reflexite Combines with ORAFOL to Create Leading Global Reflective Materials, Graphic Products, and Industrial Tapes Group

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      • August 10, 2011

        Felicia Hoeniger Selected to Editorial Board of the Journal of Multistate Taxation and Incentives

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      • July 25, 2011

        Susan Roberts Elected to Board of Directors of Connecticut Oral Health Initiative

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      • June 2, 2011

        Robinson & Cole Attorneys Present at CBIA’s 2011 Connecticut Tax Conference

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      • November 19, 2010

        Tax Attorney Speaks to UCONN Law Students about Opportunities in Corporate Law

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      • November 16, 2010

        Tax Partner Analyzes Tax Incentives for Investment and Job Growth in Connecticut

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      • November 10, 2010

        Best Lawyers Names Five Robinson & Cole Attorneys as Lawyers of the Year, Most Chosen in the Hartford Community

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      • November 9, 2010

        Attorney Moderates Panel at National Tax Conference

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      • November 3, 2010

        Tax Attorneys Present at Connecticut Society of Certified Public Accountants’ Tax360º Conference

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      • October 13, 2010

        Connecticut Bar Association Appoints Robinson & Cole Attorney as Subcommittee Chair

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      • September 30, 2010

        Tax Attorney Moderates Panel Discussion on Purchasing Digital Products

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      • August 20, 2010

        Tax Attorneys Write Summary of 2009 Connecticut Tax Law Developments

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      • July 26, 2010

        Scott Sebastian Named Cochair of Connecticut Bar Association’s Young Lawyers Section Tax Committee

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      • June 21, 2010

        Robinson & Cole Attorneys Present at CBIA 2010 Tax Conference

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      • April 12, 2010

        Robinson & Cole Tax Attorneys Present at Tax Seminars in New Orleans

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    • Publications + Presentations
    • "Virtual Economy – Ready or Not," co-presented by Ryan V. Leichsenring and Jennifer Jensen of PricewaterhouseCoopers, at the 2016 State Tax 360° Conference, held by the Connecticut Society of Certified Public Accountants in Rocky Hill, Connecticut (11/29/2016)
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      "Connecticut Tax Update, presented at the Tri-State Update hosted by the National Conference of CPAs Westchester/Rockland Chapter," presented by Ryan V. Leichsenring (12/8/2015)

      "Connecticut Special Accrual Rules, presented at the XPX meeting," presented by Ryan V. Leichsenring (10/22/2014)

      "NBI: Sales and Use Tax in Connecticut," presented by Ryan V. Leichsenring (6/17/2014)

      "Sales and Use Tax Exemptions and Credits," presented by Felicia S. Hoeniger, presented at the National Business Institute's (NBI) Sales and Use Tax in Connecticut Conference on Connecticut tax issues in Cromwell, Connecticut (6/17/2014)

      "Sales and Use Taxes for the Construction Industry," presented by Felicia S. Hoeniger, presented at the Connecticut Business & Industry Association's 2014 Connecticut Tax Conference in Farmington, Connecticut (6/13/2014)

      "CBIA 2014 Connecticut Tax Conference," presented by Ryan V. Leichsenring (6/13/2014)

      "CBIA 2013 Connecticut Tax Conference," presented by Ryan V. Leichsenring (6/21/2013)

      "Sales and Use Taxes for the Construction Industry," at Connecticut Business & Industry Association's 2013 Connecticut Tax Conference, co-presented by Felicia S. Hoeniger and Scott E. Sebastian (6/21/2013)

      Connecticut Grants Tax Amnesty (06/17/2013)

      "2012 Connecticut Tax Law Developments," published in Connecticut Bar Journal, co-authored by Felicia S. Hoeniger and Scott Sebastian (3/2013)

      Defense of Marriage Act Ruled Unconstitutional (06/04/2012)

      "Connecticut State Tax Update and Developments," presented by Felicia S. Hoeniger, presented to the New York Tax Study Group (4/23/2012)

      CT General Assembly Special “Jobs Session” Tax-Related Measures (12/14/2011)

      "A Practitioner's Perspective on CT Taxes," at 2011 University of Connecticut Tax School, presented by Felicia S. Hoeniger (11/16/2011)

      "A Practitioner's Perspective on Connecticut Taxes," at University of Connecticut Tax School, Panelist (11/16/2011)

      "To Love, Honor, and Share Tax Deductions…?" presented at Connecticut Society of Certified Public Accountants' (CSCPA) Tax360º Conference in Rocky Hill, Connecticut, co-presented by Virginia E. McGarrity, Felicia S. Hoeniger and Kelley Galica Peck (11/9/2011)

      "Refund Roadblocks," at Sales Tax Symposium sponsored by the Institute for Professionals in Taxation, presented by Felicia S. Hoeniger (9/27/2011)

      CT Majority Leaders' Job Growth Roundtable Recommendations Enacted (07/26/2011)

      The Environmental Exception and Treatment of Nonresident Contractors (07/12/2011)

      "Sales and Use Taxes for the Service Industry," at Connecticut Business & Industry Association's Connecticut Tax Conference, co-presented by Felicia S. Hoeniger and Douglas Joseph of BlumShapiro (5/20/2011)

      "Sales and Use Taxes for the Construction Industry," at Connecticut Business & Industry Association's Connecticut Tax Conference, presented by Scott E. Sebastian, attorney, and Paul Greenfield, Connecticut Department of Revenue Services (5/20/2011)

      Connecticut Budget Act and Pending Tax Legislation (05/19/2011)

      Construction Solutions - November 2010 (11/22/2010)

      Can Connecticut's Economic Nexus Rule Withstand Judicial Challenge? (11/11/2010)

      "The Brave New World of Economic Nexus in Connecticut and Elsewhere," presented at Connecticut Society of Certified Public Accountants' Tax360º Conference, Rocky Hill, Connecticut, co-presented by Felicia S. Hoeniger and Richard W. Tomeo (11/2010)

      DRS Issues Guidance on Waiver of Civil Penalties (10/21/2010)

      "Liaison Reports," at National Association of State Bar Tax Sections, San Francisco, California, presented by Richard W. Tomeo (10/2010)

      "Current Developmental," at American Bar Association's Tax Section Fall Meeting (9/24/2010)

      "Purchasing Digital Products: A Comparison of Canadian and U.S. Taxes," at American Bar Association's Tax Section Fall Meeting, Moderator (9/24/2010)

      Once Again, Connecticut Supreme Court Rejects DRS's Restrictive Reading of a Statute (09/02/2010)

      New Incentives for Connecticut Investments and Jobs (08/09/2010)

      Film Tax Credits Criteria Changed - But Incentives Left Intact (06/23/2010)

      Bradley Airport Development Zone Provides Opportunities for Investment (06/17/2010)

      "Application of Connecticut Sales and Use Tax to Construction Contractors," at Annual Connecticut Tax Forum of the Connecticut Business & Industry Association (5/2010)

      "Connecticut Tax Issues — An Overview for Property Developers and Managers," at Annual Connecticut Tax Forum, hosted by the Connecticut Business & Industry Association, presented by Felicia S. Hoeniger (5/2010)

      Successor Liability Can Snare the Unsuspecting Purchaser of Assets (05/20/2010)

      Massachusetts DOR Initiates Amnesty for Business Taxes (04/05/2010)

      "Connecticut Tax Law Developments," published in Connecticut Bar Journal, authored by John R. Shaughnessy, Jr. (2008 to 2012)

      CT Adopts and Clarifies New Safe Harbor for Withholding on Nonresident Employee Wages (01/21/2010)

      Connecticut Supreme Court: DRS Argument Won't Fly (12/11/2009)

      "Recent Developments in Taxable and Tax-Free Mergers and Acquisitions," presented by Christine E. Bromberg, at the Connecticut Society of Certified Public Accountants' Tax 360 Conference (12/2009)

      "Department of Revenue Services Sales and Use Tax Hot Topics," at "Tax 360" seminar, hosted by the Connecticut Society of Certified Public Accountants, presented by Felicia S. Hoeniger (12/2009)

      "Handling Connecticut Income Tax Audits and Hot Issues," at "Tax 360" seminar, hosted by the Connecticut Society of Certified Public Accountants, presented by Richard W. Tomeo (12/2009)

      Connecticut's Budget Act (11/09/2009)

      "Practitioners' Perspectives on Connecticut Taxes," presented at University of Connecticut 2009 Tax School, co-presented by Richard W. Tomeo and Felicia S. Hoeniger (11/2009)

      Court Says "No" to Double Tax on Construction Contracts (09/29/2009)

      "Annual Survey of Connecticut Tax Law Developments," published in Connecticut Bar Journal (1990 to present)

      "Sales and Use Tax Audit Survival Skills: How to Successfully Navigate a Sales and Use Tax Audit — and the Top 10 Mistakes Taxpayers Make," at Annual Connecticut Tax Forum, hosted by the Connecticut Business & Industry Association, presented by Felicia S. Hoeniger (6/2009)

      "Sales and Use Taxes in the Construction Industry," at annual Connecticut Tax Conference, hosted by the Connecticut Business & Industry Association, presented by John R. Shaughnessy, Jr., Panelist (2009, 2011, 2012, 2013)

      American Recovery and Reinvestment Act of 2009: Renewable Energy Incentives for Business (04/01/2009)

      "Recent Developments in Connecticut Taxation," at Tri-State Tax Conference, sponsored by the New York Certified Public Accountants Society, New York City, presented by Richard W. Tomeo (2/2009)

      Connecticut Tax Amnesty (01/21/2009)

      New York State Tax Authority Eliminates Temporary Stay Exception for Purposes of Determining Residency (01/15/2009)

      Recent MA Ruling Illustrates Differences in the Taxation of Investment Income Among CT, MA, and NY (10/24/2008)

      Potential Refund Opportunity Foreshadowed by Connecticut Tax Court Decision (06/16/2008)

      "2007 Connecticut Tax Law Developments," published in Connecticut Bar Journal, authored by Christine E. Bromberg (3/2008)

      "2006 Connecticut Tax Law Developments," published in Connecticut Bar Journal, authored by Christine E. Bromberg (3/2007)

      "State Tax Issues Affecting Businesses Expanding to Multistate Operations," at Midyear Meeting of the American Bar Association Tax Section in Hollywood, Florida (1/2007)

      "State and Local Tax Considerations Arising on Change of Entity," at Fall Joint Meeting of the ABA Sections of Taxation and Real Property, Probate, and Trust Law in Denver, Colorado (10/2006)

      "A Primer on Intellectual Property," published in Journal of Gift Planning, authored by Amy Span Wergeles (6/2003)

      "Recent Property Tax Developments in the Eastern United States," (4/3/2003)

      "Connecticut Update," at New York Foundation for Accounting Education Tri-State Taxation Conference, presented by Richard W. Tomeo (1/9/2003)

      "Application of Connecticut Sales and Use Tax to Construction Contractors," at Connecticut Society of CPAs (10/29/2007)

      "Stealth Nexus: A Look at Nontraditional Routes to Determinations of Sales and Use Tax Nexus," published in BNA Tax Management Multistate Tax Report (5/24/2002)

      "Connecticut Tax Litigation Developments," at Department of Revenue Services' Business Users Group, presented by Richard W. Tomeo (10/16/2001)

      "Connecticut Tax Developments," at Connecticut Bar Association's Annual Meeting, presented by Richard W. Tomeo (5/26/2001)

      "Tax Update—New England States," at Georgetown University Advanced State and Local Tax Institute, presented by Richard W. Tomeo (5/17/2001)

      "Connecticut Supreme Court Holds that Software Customization Is a Taxable Computer Service," published in Journal of Multistate Taxation, authored by Richard W. Tomeo (3/2001)

      "Multistate Taxation and E-Commerce – Connecticut,," published in Journal of Multistate Taxation, co-authored by Richard W. Tomeo and John Shaughnessy (3/2001)

      "What's Happening in Connecticut," at New Jersey Tax Practitioners Multistate Tax Seminar, presented by Richard W. Tomeo (11/15/2000)

      "Andersen Consulting v. Gavin,," co-authored by Richard W. Tomeo and John Shaughnessy and Linda Morkan, amicus brief filed with the Connecticut Supreme Court (9/29/2000)

      "General Assembly Adopts Single-Factor Income Apportionment for Manufacturers and Broadcasters," published in Journal of Multistate Taxation, authored by Richard W. Tomeo (6/2000)

      "Superior Court Rejects Automatic Disallowance of Foreign Sales Corp. Commission Expense," published in Journal of Multistate Taxation, authored by Richard W. Tomeo (6/2000)

      "Connecticut Supreme Court Permits Offset Against Tax Liability," published in Journal of Multistate Taxation, authored by Richard W. Tomeo (1/2000)

      "Sales and Use Tax in Connecticut," at Lorman Educational Services, Faculty (2011, 2012, 2013)

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