J. Ramsay Farah and Elizabeth Farah - Page 19




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          Hagerstown.  However, Dr. Farah’s employment history indicates he           
          stopped residing in Hagerstown in June 1998.  Around the time he            
          began work for Sierra, Dr. Farah sold his Hagerstown practice,              
          gave up his privileges at the local Hagerstown hospital, and was            
          terminated from employment with the Victor Cullen Academy because           
          he no longer lived in Hagerstown or elsewhere within a 20-mile              
          radius of the facility.                                                     
               Respondent relies heavily on the fact that petitioners used            
          the Hagerstown address on their tax returns, driver’s licenses,             
          vehicle registrations, and voter registrations.  Petitioners                
          explain that they did not change their mailing address because              
          they wanted to maintain a consistent appearance considering Dr.             
          Farah’s myriad professional and business activities, including              
          positions with various State medical boards.  Since 1980, Dr.               
          Farah has used the Hagerstown address for all of his business               
          activities.  Petitioners further argue that the addresses were              
          not changed on their tax returns, voter registrations, driver’s             
          licenses or vehicle registrations because they still resided in             
          Maryland, they still owned the Hagerstown house, they did not               
          believe that changing the address made any difference,8 and they            
          wanted all mail sent to a single address.                                   


               8In fact, petitioners’ residency affected the amount of                
          Maryland local income tax petitioners paid.  The local income tax           
          rate imposed on residents of Hagerstown is greater than that                
          imposed on residents of Berlin.  See Md. Code Ann., Tax-Gen. sec.           
          10-106 (LexisNexis 2004).                                                   





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