N.Y. Comp. Codes R. & Regs. tit. 20 § 2375.11
Personnel of the Division of Taxation, at all levels, personally communicate tax policy and interpretations to thousands of taxpayers, tax practitioners and members of the general public each year. These communications take many forms, such as letters, electronic mail, questionnaires, facsimile transmissions (FAX), telephone conversations, conferences, news media appearances and other speaking engagements. (The division's personnel also file papers and present oral arguments, or assist in such acts, in connection with administrative and judicial tax proceedings; however, such specialized communications are not within the scope of this Part.) The correspondence and oral communications of the personnel of the division, in themselves, are considered to be advisory only. They do not have legal force or effect, precedential value or a binding nature. However, these methods of communication are the basic tools by which personnel of the division interact with others and advise others as to their rights and responsibilities under the Tax Law, related statutes and regulations adopted pursuant thereto. (See article 41 of the Tax Law for taxpayers' rights concerning written and oral communications with the division.)
N.Y. Comp. Codes R. & Regs. Tit. 20 § 2375.11