In Matter of Carl Ruderman, DTA No. 826242 (N.Y.S. Div. of Tax App., July 14, 2016), a New York State Administrative Law Judge held that the Florida domiciliary petitioner, who maintained a permanent place of abode in New York City, was a statutory resident of New York State and City. The ALJ found that Mr. Ruderman, a publishing executive, failed to prove through contemporaneous records, such as a diary or other credible evidence, that he had not spent more than 183 days in New York. Although Mr. Ruderman submitted multiple affidavits from individuals, including his hairdresser, personal assistant, and concierges at his Florida residence, all stating that Mr. Ruderman was in Florida for periods ranging from weeks to months, the ALJ found the affidavits lacked specificity and were contradicted by other evidence, including credit card charges and telephone records of calls made from his New York premises on more than 200 days during the year at issue.