The imposition of tax return preparer penalties against a registered tax-return preparer, who prepared several hundred New York State personal income tax returns over a three-year period in which taxpayers claimed improper personal property rental expense adjustments, reducing their New York taxable income, has been upheld by the State Tribunal. Matter of Maria J. Garcia, DTA No. 826043 (N.Y.S. Tax App. Trib., Dec. 1, 2016). The penalties imposed, at a maximum of $1,000 per understated tax return, had resulted from a tax preparer audit investigation that employed a computer match analysis. The Tribunal rejected the tax preparer's sole arguments on appeal that the penalties were improper because the statutory penalty provision expired effective July 1, 2015, prior to the ALJ's determination in 2016, which the preparer argued constituted an improper retroactive application of the penalties.