Connecticut or Florida? A $13 Million Tax Call Comes Down to One Question

The dispute came down to where Jack Anderson actually lived

This is what a domicile fight looks like in practice: not a spreadsheet, but a $13.2 million Connecticut tax bill sent to the estate after Jack Anderson died in 2015. The estate argued that Anderson's real home was a 9,700-square-foot oceanfront mansion in Vero Beach, Florida, where he ran an observatory and celebrated Christmas. Connecticut maintained that he was still domiciled there, pointing to his condominiums in the state and Connecticut tax withholding set up for his nurses.

From about 2006 to 2015, Anderson spent roughly 5.5 months in Connecticut, 3.5 months in Florida, and 3 months in Arizona each year. That matters because domicile is not decided by a driver's license or voter registration alone. Courts look at intent and lifestyle. In this case, the court treated a Florida driver's license, voter registration, and local bank account as convenient markers, but not decisive ones: "administrative" connections to Florida said less than where Anderson actually spent his time.

The first trial still went against the estate, but the case changed procedurally when the Connecticut Supreme Court lowered the burden to preponderance of the evidence and ordered a new trial. That is why the dispute matters now: the same facts are being judged again, and the central question remains where Anderson truly lived.

Connecticut weighs many factors, but time often decides the tiebreak

The 28-factor test looks at more than paperwork

Connecticut does not decide domicile by counting paperwork boxes. It applies a 28-factor domicile test that looks at property use, social ties, daily habits, and where the person actually lived. That is why "administrative" connections to Florida did not settle the case. The court treated those moves as one-time, administrative tasks that carried less weight than the decedent's actual pattern of living.

The facts supported both sides

The estate had a real argument. Anderson's Florida home was not a spare bedroom; it was a 9,700-square-foot oceanfront mansion with a custom observatory and a place where the family celebrated Christmas. But Connecticut also had substance behind its position: Anderson kept property there and maintained Connecticut tax withholding for his nurses.

That is the core tension in multi-state domicile cases. A single luxury home does not automatically win, nor does a cluster of bureaucratic steps automatically lose. The state looks at whether the paperwork matches the way the person actually lived.

Why time mattered when the other factors balanced

The lower court found that Anderson's substantive personal, social, and property connections to Connecticut and Florida were roughly equal. When that happens, Connecticut returns to a practical tiebreaker: where was the person most consistently living?

On that point, the finding still favored Connecticut. Anderson had a regular practice of spending 5.5 months a year in Connecticut and 3.5 months in Florida. For anyone maintaining homes in multiple states, the warning is straightforward: if time use points one way, paperwork alone may not control.

What matters most when changing a multi-state domicile

The practical lesson is simple: calendar first, paperwork second. Domicile disputes turn on where a person actually lived and the intent and lifestyle they maintained, not merely on how clean the documentation looked. Courts still care most about where you spend your time.

The clearest signals are the ordinary ones:

• Time spent: Consistent physical presence matters more than almost anything else.
• Property use: If the old-state homes remain in regular use, the new home can look more like a luxury property than a true replacement base. In Anderson's case, Connecticut pointed to a trio of condominiums there.
• Administrative steps: Driver's license changes, voter registration, and bank accounts can help, but they are usually weaker than daily habits and actual time use.

The next checkpoint is the new trial ordered by the Connecticut Supreme Court. The Anderson facts did not produce a clean win for the estate the first time around, but they may be judged again under the ordinary civil standard. For multi-state taxpayers, the takeaway is simple: plan the move while it is still happening, not after the bill arrives.