N.Y. Tax Law § 1195

§ 1195. Presumption. For the purpose of the proper administration of\nthis article and to prevent evasion of the tax imposed by this article,\nit shall be presumed that every transfer of possession of a shared\nvehicle to a shared vehicle driver anywhere in this state is subject to\nthe tax under this article. This presumption shall prevail until the\ncontrary is established.\n