There may be litigation challenging a right to appeal an executive agency decision by a sister executive agency. Also, applying the new rule to pending matters may be a basis for a claim that the new law may only be applied to cases initiated after the effective date.
Many taxpayers will be faced with paying state tax twice on the same income, a result that is inconsistent with constitutional requirements of having state taxes fairly apportioned and reasonably related to the services provided by the taxing state.