Pratt v. State Tax Commission

920 P.2d 400 (1996)

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Pratt v. State Tax Commission

Idaho Supreme Court
920 P.2d 400 (1996)

Facts

William and Joy Pratt were domiciled in Idaho from July 1987 until sometime in 1991. William was employed by a bank in Boise, Idaho, until May 3, 1991, when his employment ended, and he received a termination check in the amount of $63,450. The Pratts had intended to move to Clarkston, Washington. The Pratts travelled to Clarkston in March 1991 to find housing, but they were unsuccessful. In April 1991, the Pratts found housing in Clarkston, but it was not available for lease until June 1, 1991, and they moved to Clarkston on May 31, 1991. When the Pratts received William’s termination check, they resided in Boise, their vehicles were registered in Idaho, and they each held Idaho driver’s licenses. Idaho tax law required part-year Idaho residents to pay taxes on taxable income from all sources received during the part of the taxable year they were domiciled in Idaho. The Pratts treated William’s May 3, 1991 termination check as a payment to a nonresident when they reported their 1991 income, despite living in Boise when they received the check. The Idaho Tax Commission claimed that the termination check should have been included as part of the Pratts’ Idaho income for 1991. The Pratts sought court review, and a magistrate concluded that the Pratts had not met their burden of proving a change in their domicile as of May 3, 1991, when they received the termination check. The magistrate concluded that the record lacked any evidence as to when the Pratts’ intent to become Washington residents was to take effect. Therefore, the magistrate held that the Pratts were liable for the Idaho state income tax and interest. The district court affirmed the magistrate’s decision, and the Pratts appealed. The Pratts argued that a change in domicile only requires physical presence in the new state with an intent to make it a new domicile and that they changed their domicile in April 1991 when they were in Clarkston looking for a house.

Rule of Law

Issue

Holding and Reasoning (Trout, J.)

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