A Question of Residence 

Jack Anderson ran a successful hospital management company and was an early leader of HMOs.  He and his wife, Rose Marie, lived in Greenwich, Connecticut from the late 1950s until 1970, then in Tennessee in the 1970s, and in Texas from 1980 until 2006.  In 1984 the couple purchased a 4,000 square foot condominium in Greenwich for occasional visits. In the early 1990s they built an ocean-front mansion in Vero Beach, Florida, 9,700 square feet.  They also maintained a mountaintop home in Arizona.

When Mr. Anderson died in 2015, his estate was worth $108 million.  No doubt a substantial federal estate tax was paid.  Of the three states where he owned homes, only Connecticut still had a death tax, and the exemption level in 2015 was only $2 million. The state sent a bill for $13.2 million in estate taxes.

The executor of the estate protested, arguing that Florida was Anderson’s primary permanent residence.  The Florida home was far more opulent and valuable, it was where the extended family gathered for Christmas.  Anderson had a Florida driver’s license and Florida bank accounts.

The trial court found that Anderson’s personal, social and property connections were roughly equal in Florida and Connecticut, but noted that in his last years he divided his time roughly 5½ months in Connecticut, 3½ months in Florida, and 3 months in Arizona.  The trial court held that the estate had failed to prove by clear and convincing evidence that Connecticut was not Anderson’s residence.

This past June the Connecticut Supreme Court ordered a new trial, holding that the correct standard is a preponderance of the evidence, a lower hurdle for the estate to get over.  So, eleven months after his death, the fight over state taxes will continue.

Establishing a state of primary residence is a critical estate planning question for those who divide their time between several jurisdictions.  Sixteen states continue to impose death taxes—that is, estate taxes, inheritance taxes, or both.  There have even been cases was a decedent was found to be a resident of more than one state, resulting in death tax duties to multiple states.

(September 2026)

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