In Matter of SSOV ‘81 Ltd. (N.Y. Div. Tax App., Admin. Law Judge Deter., 09/19/1996), the Tribunal explained that the term “information service” has been interpreted to mean:
“the sale of the service of furnishing information by a business whose function it is to collect and disseminate information which is taxable under Tax Law § 1105(c)(1) and not the mere sale of information”…In order to determine a service’s taxability, the analysis employed by the New York courts and the Tax Appeals Tribunal focuses on the service in its entirety, as opposed to reviewing the service components or by the means in which the service is effectuated.
In this case, the Tribunal focused on the “primary function” of the service, which was to enable members of
“the sale of the service of furnishing information by a business whose function it is to collect and disseminate information which is taxable under Tax Law § 1105(c)(1) and not the mere sale of information”…In order to determine a service’s taxability, the analysis employed by the New York courts and the Tax Appeals Tribunal focuses on the service in its entirety, as opposed to reviewing the service components or by the means in which the service is effectuated.
In this case, the Tribunal focused on the “primary function” of the service, which was to enable members of