New York Laws
Article 2-D - City Personal Income Tax on Residents
25-A-17 - Resident Partners.

(b) Character of items.--Each item of partnership income, gain, loss,
or deduction shall have the same character for a partner under this
local law as for federal income tax purposes. Where an item is not
characterized for federal income tax purposes, it shall have the same
character for a partner as if realized directly from the source from
which realized by the partnership or incurred in the same manner as
incurred by the partnership.
(c) City tax avoidance or evasion.--Where a partner's distributive
share of an item of partnership income, gain, loss or deduction is
determined for federal income tax purposes by special provision in the
partnership agreement with respect to such item, and where the principal
purpose of such provision is the avoidance or evasion of tax under this
local law, the partner's distributive share of such item, and any
modification required with respect thereto, shall be determined as if
the partnership agreement made no special provision with respect to such
item.

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