A New York state administrative law judge has decided that billionaire Julian H. Robertson Jr. did not spend enough days in New York City for purposes of exposing himself to tens of millions of dollars’ worth of city tax liability in 2000.

State tax auditors had tried to show that the financier spent the requisite 183 days as a city resident and was subject to $26.7 million in city income taxes and another $21 million in interest for that year alone.