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Robertson’s driver had to be on alert: as long as they crossed the Queens border en route to Locust Valley by midnight, Robertson didn’t have to “waste” a Saturday as a New York day.Even one minute of a day spent in the city counts as a day of residence.The Internal Revenue Service discloses detailed statistics for the four hundred highest-earning taxpayers in the country.

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Republicans don’t defend the current tax code, either.

Even a flat tax, whereby taxpayers at all income levels pay the same rate—a concept embraced in varying degrees by some candidates and advanced by the conservative Heritage Foundation—would likely raise rates on the ultra-wealthy.

(Exceptions are made for people who are in transit from one destination outside the city to another—from Newark airport to Long Island, for example, or to La Guardia for a flight.) Robertson said he never missed the midnight deadline, although when he couldn’t get his driver or a limousine service in time he occasionally had to hail a cab.

On one occasion, Robertson came back from a trip and found himself crossing into Manhattan at .

Whenever the combined number fell below a hundred and eighty-three, she advised him to add more non-New York City days to his schedule.

She said that she reminded him “ad nauseam” about what he needed to do to reach a hundred and eighty-two non-New York City days.

That mistake cost him a full New York City day, which he could have avoided by whiling away fifteen minutes at the airport.

According to Depperschmidt’s meticulous calculations, by the end of the calendar year 2000 Robertson had recorded a hundred and eighty-three New York City days, the exact number allowed by statute, and a number all but guaranteed to raise red flags, because it came so close to the line.

Thirty of them paid less than ten per cent in federal taxes, and a hundred and one paid between ten and fifteen per cent.

On average, the group paid 18.1 per cent—a lower rate than taxpayers who earn between two hundred thousand and five hundred thousand dollars.

In September of 2006, five years after the return was filed, the Division of Taxation announced its initial findings: Robertson had been outside the city on a hundred and seventy-nine days, meaning that there were just four days in dispute.