Goldstein v. Tax Appeals Tribunal

*1497The Department issued notices of disallowance regarding the additional interest sought by petitioners. The Department determined that, pursuant to Tax Law former § 688, interest on an amended return was allowed from the date of filing of the amended return and not the date the original return was filed. The Administrative Law Judge (hereinafter ALJ) noted that, under the statutory language now in effect, interest on an amended return is permitted from the original filing date, but such statutory language did not become effective until January 1, 1999. Since the years in question predated the…