The Tax Appeals Tribunal, affirming an ALJ decision, has upheld the taxation of a portion of the compensation received by a nonresident individual from exercising stock options for personal income tax purposes. Matter of Lawrence Gleason, DTA No. 823829 (N.Y.S. Tax App. Trib., Mar. 18, 2014). The individual, a retired American Airlines employee, had received incentive nonstatutory stock options as an employee, which he exercised in 2006 after his retirement, and then sold the stock, but did not allocate any portion of the gain to the State. The taxpayer argued, among other things, that since the value of the stock appreciated after he retired, the resulting gain had no connection with his New York employment. The Tribunal held that, under Michaelson v. NYS Tax Comm’n, 67 N.Y.2d 579 (1986), the gain was properly subject to tax. Noting that the taxpayer did not challenge the Department’s calculation of the allocable portion of the gain, the Tribunal held that the ALJ “accurately and adequately” addressed the manner in which the taxable portion of the gain was determined.