New Tax Tribunal Ruling on Change-of-Residency Challenges

There seems to be an increased number of so-called “residency audits” being conducted by the Alabama Department of Revenue (ALDOR), as well as by other state tax authorities. These audits often result from the taxpayer filing a federal income tax return listing an Alabama address, while not having filed an Alabama return, or receiving a W-2 listing an Alabama address. The ALDOR receives notice of this discrepancy through its exchange of information agreement with the IRS. The Alabama Tax Tribunal (ATT) has issued a number of rulings on this issue in the past few years, including a recent (and very instructive) ruling by Judge Leslie Pitman.