## Facts

- John T. Dorrance, a Campbell Soup Company executive, was born and originally domiciled in Pennsylvania, later moving to New Jersey and living for years at a family home in Cinnaminson, New Jersey.
- In 1925, Dorrance purchased “Woodcrest,” a large estate in Radnor Township, Delaware County, Pennsylvania, and moved there with his wife and children.
- After the move, the family’s day-to-day life centered at Woodcrest: the children attended school in Pennsylvania and the family’s social activities were largely based there.
- Dorrance continued commuting from Woodcrest to his business in Camden, New Jersey.
- Dorrance retained ties to New Jersey, including continued ownership of the Cinnaminson property (occupied by his mother and sister until their deaths in 1928 and 1929) and consistent payment of personal taxes in New Jersey.
- Dorrance made repeated formal declarations describing himself as a New Jersey resident, including in tax filings and his will, and directed probate in New Jersey; evidence indicated these declarations were driven largely by tax advantages.
- Dorrance also maintained a summer residence in Bar Harbor, Maine; he spent the summer of 1930 there, returned to New Jersey, and died in New Jersey on September 21, 1930.

## Issues

1. Whether Dorrance was domiciled in Pennsylvania at death, making his intangible personal property subject to Pennsylvania transfer inheritance tax.
2. How courts should weigh tax-motivated declarations of residence against objective evidence of a decedent’s “real family home” and principal establishment when multiple residences exist.

## Decision

- The Pennsylvania Supreme Court reversed the Orphans’ Court decree that had set aside Pennsylvania’s tax appraisement.
- The court held that Dorrance was domiciled in Pennsylvania at the time of his death.
- The court reinstated the Commonwealth’s transfer inheritance tax appraisement on Dorrance’s intangible estate, subject to agreed valuation modifications.

## Legal Principles

- Domicile is the place of a person’s real family home and principal establishment, kept for an indefinite time and not merely for a temporary purpose.
- A domicile of choice requires both physical presence in the alleged domicile and intent to make it the person’s home.
- An existing domicile is presumed to continue until a new domicile is acquired in fact and intent; the party asserting a change bears the burden of proof.
- Statements and documents declaring residence are not controlling when inconsistent with objective circumstances; conduct showing where the family home is actually established may outweigh self-serving declarations, including those motivated by tax consequences.
- When a person maintains multiple residences, domicile is determined by identifying the principal establishment and true family home rather than seasonal or secondary residences.

## Conclusion

Because Dorrance’s family life and principal establishment were centered at Woodcrest in Pennsylvania, the court found he had acquired a Pennsylvania domicile despite continued New Jersey ties and formal New Jersey residency declarations, and Pennsylvania could tax his intangible personal property through its transfer inheritance tax.


In re Dorrance's Estate, 309 Pa. 151 (Pa. 1932)