The treatment of deferred compensation plans is one of the more complex areas of taxation since there are many different types of arrangements, including deferred cash payments, grants of stock and stock options, and other methods. Determining the New York taxation of nonresident employees who receive deferred compensation adds an additional level of complexity. The recent administrative law determination in Petition of Dale Adams (DTA No. 850026 (2024)) demonstrates the difficulties taxpayers, auditors and judges have in deciding how to apply the relevant provisions of the Tax Law.