In Allen v. Commissioner, 324 Conn. 292 (2016), the Connecticut Supreme Court did not permit a Connecticut taxpayer to seek a refund in connection with a late-filed tax return because the return was filed more than three years after its original due date—even though the tax year was still open for examination by the Department of Revenue Services.
The Supreme Court further determined in Allen that income from the exercise of nonqualified stock options should be considered Connecticut source income if the options were granted while the taxpayer was a resident of Connecticut—even though the options were exercised and the resulting income arose for tax purposes after the taxpayer ceased to be a resident of Connecticut.
In Allen, the Supreme Court exercised its ability to directly decide on Appellate Court matters and upheld the Superior Court’s overall findings in Allen v. Sullivan, No. CV 11 6010197, ...
