On April 22, 2026, Justice Reed of the New York County Commercial Division issued a decision in Slice Wireless Servs., LLC v. Yakubov, 2026 NY Slip Op. 50568(U), holding that tax records are discoverable only when they are indispensable, explaining:
Finally, to justify the mandatory disclosure of corporate tax returns a party must establish that the information contained within the tax return is indispensable to the litigation and unavailable from other sources. Here, the court is satisfied that defendants complied with their discovery obligations in providing tax records for the period of 2017-2018. This court declines to order the disclosure of additional corporate tax records as there has been no showing that the information sought could not be obtained from alternative sources, and no showing of any indispensable need for the information sought.
(Internal quotations and citations omitted).