Jefferson Allen v. Commissioner of Revenue Services

Summary

The court held that the plaintiffs' refund claim for 2002 was barred by the statutory three-year filing period, which was a condition of the state's limited waiver of sovereign immunity and deprived the trial court of subject matter jurisdiction. It further held that Connecticut's regulation permits taxation of nonqualified stock-option income when the options were granted as compensation for services performed in Connecticut, even if exercised after the taxpayer moved away. The court also concluded that this taxation satisfied due process because the services performed in Connecticut supplied a sufficient nexus to the state.