A New York City Administrative Law Judge held that the Department of Finance properly invoked its authority to disregard the method of accounting employed by a corporate taxpayer in order to include all of the taxpayer's gain from an installment sale of real property in the taxpayer's final General Corporation Tax return. Matter of 1018 Morris Park Avenue Realty Inc., TAT(H) 144(GC) (N.Y.C. Tax App. Trib., Admin. Law Judge Div., Dec. 5, 2016). The ALJ also held that the taxpayer failed to prove that it continued to be subject to tax merely because it maintained a bank account, and therefore should not have filed a final GCT return, which would have allowed it to report the gain based on when the installment payments were received. According to the ALJ, the record "reveal[ed] a striking dearth of relevant proof" that the taxpayer continued to have any operations in New York City after the year at issue.