There was a famous radio commentator who passed away earlier this year. He moved from NYC to Florida a number of years ago. Even though he had no property in NY and spent few if any nights there, the state auditors still came after him every year. The audits were nit picky. He owned no taxes, but had to spend thousands each year in CPA (and legal?) fees each year to disprove their conjectures. Part of it may have been auditors’ interest in a big time tax payoff, part may have been political revenge. But it was a royal pain for him, each and every year.