This article responds to an analysis of Lunding v. N.Y. by Professor Ferdinand P. Schoettle, who argues in favor of the taxpayer in the case relying on free-market economic values. Professor Schoettle criticizes Professor Michael J. McIntyre and Richard D. Pomp's defense of New York's tax laws...

Under New York law at this time, non-resident taxpayers were only permitted state income tax deductions for expenses reasonably related to income earned in the state. Residents could deduct alimony payments, but non-residents could not because such expenses were considered wholly personal. Prior...