NY Justices Quiz Firm Over Taxability of Software-Driven Service

Nov. 17, 2025, 7:48 PM UTC

A New York appeals panel seemed inclined at oral arguments Monday to uphold a sales tax bill of nearly $1 million on software used by a company that helps clients find temporary workers.

Beeline.com Inc. wants the New York Supreme Court, Appellate Division, Third Department to overturn a 2024 tax tribunal ruling that the company is selling taxable pre-written software.

Beeline attorney Michael Bowen of Akerman LLP argued instead that the company merely uses the software as part of what is essentially a “matchmaking service.”

“Isn’t that done by use of this software?” Justice Elizabeth A. Garry asked. “Isn’t the ...

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