New Trend In Residency Audits?

Over the past few weeks, several of our clients have received letters from the New York Tax Department's desk audit unit inquiring about their 2018 tax return. These have all been form letters, all asking the same questions, and looking something like this letter. From what we can tell, all of these letters have been issued to taxpayers who fall generally in the same circumstances: they either changed their residency during 2018 and thus filed a part-year resident return, or they filed as New York residents in 2017 and then as full-year nonresidents in 2018.

What is going on here? Normally the Tax Department would just open up a full field audit of taxpayers like this, sending a full "Information Document Request" (IDR), looking for a copy of the tax returns, a nonresident questionnaire, day-count data, etc. These more formal field audits are conducted by one of the many residency field auditors located in the district offices across New York State. These new