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perform her management duties with the Boonsboro Partnership, Ms.
Farah rarely went to the Boonsboro building. She handled all
bills and tenant issues by mail or by phone from Berlin.
Although they spent little time in Hagerstown, petitioners
always used the Hagerstown address as their mailing address.
They used the Hagerstown address on their voter registrations,
their vehicle registrations, their driver’s licenses, and on all
Federal and State income tax returns. During the relevant years,
Maryland imposed a local income tax based on the county in which
the taxpayer lived. Although the rates changed year to year, a
taxpayer domiciled in Hagerstown paid a tax rate of approximately
2.5 percent, while a taxpayer domiciled in Berlin paid only 1
percent during the relevant period. See Md. Code Ann., Tax-Gen.
sec. 10-106 (LexisNexis 2004).
All bills associated with the Berlin house were sent to
Hagerstown. Petitioners also used the Hagerstown address as
their mailing address for two shoreline construction permits
obtained for the Berlin house.
Petitioners did not stop water or utility service to the
Hagerstown house at any time. Both water usage and electricity
usage remained consistent from July 1997 through January 2007.5
5The average quarterly water usage at the Hagerstown house
from July 15, 1997 through Oct. 12, 2001 was 128.22 units. The
average quarterly water usage at the Hagerstown house from Oct.
12, 2001 through Jan. 23, 2007 was 113.45 units. The average
(continued...)
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