05/20/2026
Worth a read for anyone planning the snowbird move!
From our co-founder Kurt Supe ( on X).
They did everything the checklist told them to do.
They still owed $60,000 in back taxes.
A couple, 67 and 65. Bought a place in Florida. Spent about 5 months a year there. Kept the home up north.
Told everyone they were "basically Florida residents now."
3 years later, the audit letter arrived from their old state. Cell phone records. Credit card statements. Doctor visits. Utility bills.
The verdict: Not Florida residents. Back taxes plus interest plus penalties.
This isn't hypothetical.
In October 2025, the New York Tax Appeals Tribunal ruled against John Hoff and Kathleen Ocorr-Hoff in Matter of Hoff & Ocorr-Hoff. Tax years 2018 and 2019. Roughly $60,000 in back New York taxes.
They had done everything the checklists say to do.
Florida driver's licenses. Florida voter registration. Declaration of domicile filed in Florida. Vehicles registered in Florida. Estate planning documents updated to Florida law.
The Tribunal still ruled against them.
Here's what actually beat them.
Their Verizon cell records showed they spent more days in New York than Florida both years. 186 days in NY in 2018. 164 in 2019.
He still owned and ran a New York business and drew a significant salary. She still operated her business out of Rochester, New York. They kept two country club memberships in New York and one in Florida.
The center of their actual life never left.
The 183-day rule is the starting gun. Not the finish line.
You can be under 183 days in your old state and still lose. If your business, your income, your doctors, and your daily life stayed behind.
States are aggressive about this. New York alone collected more than $3 billion through residency audits from 2022 to 2023.
A driver's license won't save you. Neither will a declaration of domicile.
Here's what does.
Moving the substance of your life. Not just the paperwork. Your business. Your income. Your doctors. Your daily relationships. Your time.
This is why we plan domicile changes years before the move. Not after.
You're not changing your address. You're changing where your life is.
If you or someone you love is thinking about the snowbird move in retirement, save this post. The paperwork is the easy part.