New York Laws
Article 13 - Tax on Unrelated Business Income
291 - Meaning of Terms.

(b) The term "taxpayer" means an organization or trust described in
section two hundred ninety.
(c) The term "tangible personal property" means corporeal personal
property, such as machinery, tools, implements, goods, wares and
merchandise, and does not mean money, deposits in banks, shares of
stock, bonds, notes, credits or evidences of an interest in property and
evidences of debt.