Advisory opinions will be issued to the petitioner within 90 days of receipt of a completed petition for advisory opinion or the latest submission by the petitioner modifying the petition. The 90-day period within which an advisory opinion must be rendered may be extended by the Commissioner of Taxation and Finance for a period of up to 30 additional days. The period within which an advisory opinion must be issued may also be extended by agreement between the petitioner and the division.

An advisory opinion will identify the petitioner to whom it is addressed by name, address, identification number and, where applicable, taxable years or periods involved. It will contain:

All issued advisory opinions will be published and made available to the public. Before publication, all names, addresses, and identification numbers will be redacted. Additional information may be redacted if requested in the petition and if, in the division’s sole judgment, the information would, for purposes of Public Officers Law section 87.2(d), constitute a trade secret or is information that, if disclosed, would cause substantial injury to petitioner’s competitive position. The petitioner must clearly identify the information requested to be redacted in the original petition and the basis for requesting redaction. Published advisory opinions are available upon request and are also posted on the department’s website.