Every taxpayer that has participated in a New York reportable transaction during its taxable year is required to disclose its participation with its tax return for that taxable year in the manner and form prescribed by the commissioner. The fact that a transaction is a New York reportable transaction shall not affect the legal determination of whether the taxpayer's treatment of the transaction is proper.
N.Y. Comp. Codes R. & Regs. Tit. 20 § 2500.2