In the case before Sacca, the Division of Taxation and Puccio both stipulated that Puccio had spent 111 days in New York City and 80 in Connecticut and argued over the other days.
Puccio, who was represented by Gregory A. Lee, of PricewaterhouseCoopers, also presented affidavits from the managers of two wine stores, a hardware store and a pharmacy in Connecticut stating that he had shopped there on specific dates.
New York demands anyone who spends more than 183 days in the state pay taxes as a resident, regardless of where his or her main home is, and on his 2003 return Puccio indicated he was in New York for just 115 days.