Gift Tax Contested Tax Case Docket # 11 REV 14832 - 07/17/2013

Issue: I. Did Petitioners meet their burden of proving a change in their North Carolina domicile by showing: (1) an actual abandonment of the first domicile, coupled with an intention not to return to it; (2) the acquisition of a new domicile by actual residence at another place; and (3) the intent of making the newer residence a permanent home? II. Did Petitioners meet their burden to show that the Department improperly imposed the large tax deficiency penalties? III. Did the ALJ improperly abate interest on the assessments?