Affirming a decision by the New York State Tax Appeals Tribunal (covered in the August 2011 issue of New York Tax Insights), the Appellate Division, Third Department, upheld the denial of interest on an overpayment sought from the due date of the original income tax return, holding that the statute as it existed during the years in issue mandated that interest was payable only from the date of the amended return. Matter of Michael A. Goldstein A No. 1 Trust v. Tax App. Trib., 2012 NY Slip Op. 9109 (3d Dep’t, Dec. 27, 2012). The taxpaying trusts argued that significant inequity resulted from the fact that, because of federal changes reducing the taxable income of the trusts, the taxable income of the trusts’ beneficiaries increased, and the beneficiaries were required to pay interest from the dates of the filing of their original returns. Nonetheless, the Third Department held that the statute clearly did not permit the payment of interest from the due date of the original return, until the statute was amended for precisely that purpose for years beginning in 1999, two years after the last of the years at issue in this case.