Just some quick research on a post by Village Pub on the iFUD board. I didn't read all of it (after all it is almost 2 AM), but I believe this is what he is talking about. . .
http://law.onecle.com/new-york/tax/TAX0282_282.html
http://law.onecle.com/new-york/tax/TAX0282_282.html