The Idaho State Tax Commission found an individual taxpayer remained domiciled in the state and thus liable for Idaho individual income taxes where there was no evidence he ever abandoned his Idaho domicile. The taxpayer was audited and issued a notice of deficiency determination because the taxpayer did not file a tax return in Idaho for the years at issue. The taxpayer protested the deficiency determination and the commission held that the taxpayer was domiciled in Idaho for income tax purposes explaining that a “domicile” includes both residency and an intent to remain. The commission reiterated that the two most determinative factors for determining domicile in Idaho are where an individual lives and where an individual votes, but that other factors may also be relevant. The commission found that although the taxpayer did not reside in Idaho during the entirety of the years at issue, the taxpayer was raised in Idaho, returned to Idaho whenever he was not employed outside the state, and offered no evidence of any place resembling a residence or dwelling of permanence in any state other than Idaho. Accordingly, the commission affirmed that taxpayer was domiciled in Idaho during the tax periods at issue and upheld the assessment.
Idaho State Tax Comm’n, Comm’n Dec. Docket No. 1-802-528-768 (Feb. 1, 2021).