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A New York City Administrative Law Judge held that a New Jersey S corporation (“Taxpayer”) was subject to New York City general corporation tax (“GCT”) on gain from the sale of a minority limited partner interest in a limited partnership that leased and managed New York City real estate. The Taxpayer argued that the gain was from an intangible not used in its trade or business, and the gain should therefore be sourced to its domicile and excluded from its taxable income for GCT purposes. The ALJ disagreed, citing a City regulation that says a corporation will be treated as “doing business” in the City for GCT purposes if it holds a limited partner interest in a limited partnership that does business in the City. In the Matter of Mars Holdings, Inc., TAT(H)16-14(GC) (NYC Tax Trib., ALJ Div. June 26, 2020)).