Supreme Court of Kansas
Bicknell v. Kansas Dept. of Revenue
May 20, 2022
Summary
The court reversed the Court of Appeals and affirmed the district court's determination that Gene Bicknell was domiciled in Florida for Kansas income-tax purposes in 2005 and 2006. It held that venue was proper in Crawford County, that Bicknell retained the burden of proving a change in domicile, and that the district court neither shifted that burden nor lacked substantial competent evidence for its findings. The court also held that the spousal-domicile presumption could be rebutted by affirmative contrary evidence without proof that the spouses lived apart.