RCA International Development Corp. v. New York City Tax Appeals Tribunal

Initially, I disagree with the majority’s determination that we should defer to respondent’s expertise, since deference is not given to an administrative agency with respect to questions of law, such as when the agency applies a statute or its own regulations. “Where the interpretation of a statute or its application involves knowledge and understanding of underlying operational practices or entails an evaluation of factual data and inferences to be drawn therefrom, the courts regularly defer to the governmental agency charged with the responsibility for administration of the statute. If its…