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Complex domicile issues in tax cases make for interesting competing narratives, P.1

Income tax disputes can sometimes involve complex technical questions. These issues can involve not only the amount and type of income due, but also the status of the taxpayer, as in the case of Greg Blatt, CEO of Match Group—the company that owns and operates several online dating sites, including Match.com.

Blatt was successful in a New York income tax dispute this month in which he had been sued for over $400,000 in city and state income taxes, interest and penalties from the tax years 2009 and 2010. Blatt had previously lived in New York, but had moved to Texas to take on the CEO role for Match Group, which is headquartered in Dallas, only later to return to New York. 

In the tax dispute, Blatt argued that when he accepted the Match Group CEO position, the company had initially permitted him to continue to be based out of New York, to keep his New York apartment, and to keep his former corporate positions with InterActiveCorp, the owner of Match Group. Relatively quickly after making the switch to Match Group, Blatt renegotiated the agreement to make the Texas office his home base and listed his New York apartment, eventually moving his dog to Dallas, which the court apparently saw as a big step in switching Blatt’s domicile. That was in 2009. Later, Blatt ended up taking a CEO opening for InterActiveCorp, which resulted in him moving back to New York City in 2011 and working primarily from there while continuing to periodically travel to Dallas.

According to New York, Blatt was not domiciled in Dallas in 2009 and 2010, the tax years in dispute. Some of the facts they cite are that he continued to own his apartment as before, continued to own and use a boat located in New York, and eventually bought another New York residence when his Manhattan apartment sold.

In our next post, we’ll continue looking at this case, as well as the difference between domicile and residency, and how it can impact income tax reporting

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