In Matter of Zelinsky v. Tax Appeals Trib. of State of N.Y. (1 N.Y.3d 85, 801 N.E.2d 840, 769 N.Y.S.2d 464 (2003), the Court found the minimal connection called for by due process on account of the taxpayer's "physical presence in New York and because he . . . purposefully availed himself of the benefits of an economic market in" New York (Zelinsky, 1 N.Y.3d at 97). In Zelinsky, the taxpayer was a professor at Cardozo Law School who did all his teaching in New York City, and commuted there from his Connecticut home three days a week. On the other two days, "he stayed at home, where he prepared examinations, wrote student recommendations, and conducted scholarly research and writing" (1 N.Y.3d at 89). He also "worked exclusively at home" when school was not in session, and when he was on sabbatical leave (id.). In rejecting his attempt to allocate much of his law school salary to work done outside New York, we noted that a contrary ruling would allow the taxpayer to manipulate the system. The Court said: "The convenience test was originally adopted to prevent abuses arising from commuters who spent an hour working at home every Saturday and Sunday and then claimed that two sevenths of their work days were non-New York days and that two sevenths of their income was thus non-New York income, and either free of tax (if the state of their residence had no income tax) or subject to a lower rate than New York's. In the present case, the taxpayer's efforts to reduce the amount of tax owed to New York on his New York source income earned during the work week raise similar concerns."(Id. at 92 )