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Conflict of Laws Keyed to Kay, 11th Ed.
Franchise Tax Board of California v. Hyatt
Citation:
139 S. Ct. 1485 (2019)Facts
Gilbert Hyatt was a long-time California resident who in 1991 claimed to have moved to Nevada, a state with no personal income tax. He sold his California house, rented a Nevada apartment, and established various indicia of Nevada residency. When filing his 1991 and 1992 tax returns, he claimed Nevada as his primary residence. The California Franchise Tax Board suspected Hyatt’s move was fraudulent and launched an extensive audit investigation. During this audit, Board employees traveled to Nevada, conducted interviews with Hyatt’s estranged family members, shared his personal information with business contacts, and sent over one hundred letters and demands for information to third parties. The Board ultimately concluded that Hyatt had not actually moved to Nevada until April 1992 and assessed him more than ten million dollars in back taxes, interest, and penalties. In 1998, Hyatt sued the Board in Nevada state court alleging various torts committed during the audit process.
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