Sec. 132.12. Income and deductions partly from New York State sources—general

Tax Law, § 632(c)

(a) Since the New York adjusted gross income of a nonresident individual takes into account only items of income, gain, loss and deduction derived from or connected with New York State sources, an apportionment and allocation of items of income, gain, loss and deduction is required when a nonresident individual, or a partnership in which a nonresident individual is a member, carries on a business, trade, profession or occupation partly within and partly without New York State.

(b) When a nonresident individual is the beneficiary of an estate or trust, his New York adjusted gross income also includes those items of income, gain, loss and deduction, or portion thereof, included in his share of a net change (see section 139.3 of this Article) from New York State sources allocable from such estate or trust.