New York City is roughly 41° north of the equator, along the curved surface 
of the ball-shaped Earth.  In order for the sun to be at the Zenith ... to be 
90° above the horizon and shine straight down on New York ... the equator 
would have to be tilted 41° away from the plane in which the Earth's orbit 
lies.  But it isn't.  It's only tilted about 23.5° away from that plane. So the 
sun can never be directly overhead at any place that's more than 23.5° 
away from the equator.