The last installment of this column discussed New York State and City's express "decoupling" from certain changes to the federal tax law made by the CARES Act. A recent administrative law judge determination, Mars Holdings, Inc., TAT(H)16-14 (GC) (N.Y.C. Tax App. Trib., June 26, 2020), highlights the question of whether and how federal tax principles apply to New York state and city taxes in situations other than an express decoupling.