In Matter of Michael C. Schrenkel, DTA No. 826172 (N.Y.S. Div. of Tax App., July 21, 2016), a New York State Administrative Law Judge upheld an assessment of personal income tax against an individual who had failed to filed New York State personal income tax returns for 2006, 2007, and 2008. Relying primarily upon information obtained from the IRS, the Department issued notices of deficiency, and agreed to certain adjustments after reviewing records, but declined to allow additional claimed itemized deductions for mortgage interest and real property taxes. The ALJ found that the individual had failed to sufficiently demonstrate payment of interest and property taxes, noting that the record actually showed that the property had been foreclosed upon, which if anything indicated that the mortgage payments, which would have included the interest, and tax payments had actually not been made.