The rules of practice and procedure contained in this Part are intended to provide the public with a clear, uniform, rapid, inexpensive and just system of resolving controversies with the Division of Taxation of the New York State Department of Taxation and Finance. In this Part, the Tax Appeals Tribunal has set forth rules of practice and procedure to afford the public both due process of law and the legal tools necessary to facilitate the rapid resolution of controversies, while at the same time avoiding undue formality and complexity.

This Part shall govern all proceedings before the Division of Tax Appeals in which a hearing is permitted or required by the Tax Law.

This Part shall be liberally construed to secure the just, speedy and inexpensive determination of every controversy, and shall not be construed to limit or repeal rights afforded or requirements imposed by statute or otherwise.