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Federal taxes don't. The IRS doesn't maintain state tax records. :lamo
Correct. I'm unclear on what your point is. NY has an independent estate and gift tax system, but it piggybacks off federal law. Point is if it was illegal under federal law it's almost certainly illegal under NY law and they can and do engage in their own audits and prosecutions of NY state tax laws, completely independent of the Feds.
I don't know what the statutes are in NYS or what they were at the time, but that's not what we're discussing.