For many years, we have periodically reminded readers of this column of the uncertainties encountered in deciding whether transactions in the "knowledge" industry are subject to New York sales tax, a tax that was originally designed to tax the sales of tangible personal property. Nevertheless, as the world marches into the third decade of widely available electronic resources, distinguishing among consulting services, information services, and the provision of software, and then applying the differing sales tax rules to them, becomes only more difficult. The recent administrative law judge determination in MarketShare Partners, DTA No. 828562 (N.Y. Div. Tax App., Dec. 3, 2020) provides a rich text for those trying to classify a business as fitting into one of these categories.