It may be said that the classic phrase “love means nothing to a tennis player” applies equally to tax practitioners. To counter this affront, in belated observance of Valentine’s Day, this column celebrates the case of a man who was able both to reunite with his high school sweetheart in Paris and also to prevail over the claims of the New York State Department of Taxation and Finance. In a case from last summer, the administrative law judge (ALJ) in Stephen C. Patrick, et al., DTA Nos. 826838, 826839 (N.Y. Div. Tax App., June 15, 2017), determined that petitioner had changed his domicile to Paris from New York. This case may be heartening to the many taxpayers who, due to the recently enacted limitations on deductions for state and local taxes, are now considering moving their domicile out of New York. Keep in mind, however, that the petitioner in this case had unusual (and unusually helpful) facts.
Petitioner Stephen C. Patrick and Clara Scurati-Manzoni first met at a dance in 1965 and became high school sweethearts in Mamaroneck, N.Y. After high school, petitioner went to West Point Prep and Clara went to a nunnery in Italy. About a year and a half after their geographic separation, Clara announced she was marrying another man. The couple did not communicate for some four decades thereafter.
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