The New York City Tax Appeals Tribunal upheld the determination of an ALJ, and held that a payment of real property transfer tax by check is made on the date the check is delivered to the Department. Matter of Jamestown, L.P., TAT (E) 14-8 (RP) (N.Y.C. Tax App. Trib., Jan. 31, 2018). As an application for a refund of RPTT must be made within one year of payment, the Tribunal held that the taxpayer’s refund request was time-barred. The Tribunal also clarified that the fact that a year is a leap year is disregarded when making this calculation, which is properly determined by counting 365 days from the date of payment.