The U.S. Supreme Court refused to review New York's rules for taxing individuals who work in New York but only live there part time. Two cases were involved, each of which involved intangible income from the sale of a closely held business located in New York. The individuals in both cases had a residence in New York but lived primarily in Connecticut. The individuals paid taxes on the income to both Connecticut and New York. New York refused to allow the individuals to claim a New York income tax credit for the taxes paid to Connecticut because the income was from economic activities in New York. Thus, the individuals were double taxed on the income. The taxpayers argued unsuccessfully that New York was discriminating against interstate commerce.
Mr. Hendel has been practicing wealth preservation planning for over thirty years.