I'm pretty confident that this is consistent across states, you don't have a state income tax obligation from wage income alone unless you physically work/reside in the state.
Specifically from NY's tax website, a company would have to withhold taxes for:
- New York State residents earning wages even when earned outside of the
- New York State nonresidents being paid wages for services
performed within the state
- New York City residents even when services
are performed outside New York City
And similarly, a non-resident would have to file a return if:
- You are a nonresident with New York source income and your New York
adjusted gross income Federal amount column (Form IT-203, line 31)
exceeds your New York standard deduction.
- You want to claim a
refund of any New York State, New York City, or Yonkers income taxes
withheld from your pay.
- You want to claim any of the refundable or
carryover credits available.
- You had a net operating loss for New
York State personal income tax purposes for the tax year, without
having a similar net operating loss for federal income tax purposes.
Finally, New York source income is a host of things, but for wages it is limited to services performed in New York State.
If your company erroneously withheld NY income tax, you'd file a NY NR return to get that back, but otherwise your wage income alone creates no NY state filing obligation or tax burden.
The Edward Zelinsky case is more quibbling over percentages for people who already have a non-resident filing requirement because they did physically work in the state some of the time.