The New York State Division of Tax Appeals has held that Martha Stewart was a New York resident during 1992, earned taxable income in New York in 1991, and must pay income taxes.

Stewart, the fabulously successful author and television host known for her gardening, entertaining and home styling tips, had challenged a $221,677.82 tax bill, claiming she did not live in New York the requisite 183 days of the tax year and that much of her earnings were off-limits to state and city tax collectors. She also fought penalties imposed for failure to retain appropriate records on residency and income allocation issues, blaming the shortcomings on her tax preparers.