After remanding the case to an Administrative Law Judge for a more complete analysis of how the rollover of an otherwise qualifying SUNY pension by a retired SUNY professor into an IRA changed the nature of the pension, the New York State Tax Appeals Tribunal has affirmed the ALJ's determination that a distribution from the IRA did not qualify for the 100% exclusion from the personal income tax for pensions paid to State employees. Matter of Peter and Marguerite Kane, DTA No. 824767 (N.Y.S. Tax App. Trib., Dec. 21, 2016). The Tribunal concluded that an employer-sponsored retirement plan is fundamentally different from an IRA, justifying different tax treatment, despite the fact that the IRA was funded with a rollover from a pension that would have qualified as generating tax-free income if it had not been rolled over. The Tribunal relied on what it found to be significant differences in the IRA from the original pension, including the sole control over the IRA by the employee, funding of the IRA by the employee rather than by the State employer, and the ability of the employee to make further deposits into the IRA.