Address review – October 2019

For all of my adult life I’ve had more than one address. Occasionally government entities and agencies have launched investigations or made complaints about my address. I suspect this is politically motivated but I have no proof. Those government actions have accelerated lately and I anticipate more aggressive prosecutions in the future. The tension is heightened by occasional threats of physical violence; in fact one highly publicized physical assault occurred right on my front lawn in view of my family. I do occasionally worry about “copycats” and have written elsewhere about the extraordinary security measures I take now. It’s not that these measures can protect me, but rather they can provide a paper trail later.

The background, without straying into the weeds, is that I’ve been a whistleblower on more than one unrelated criminal activity. Yes, the statistical odds are against this happening more than once to one person, but that’s what happened. My outspokenness and willingness to write about risky behavior increase my exposure to unwanted critical attention. My friends joke that it is risky to hang around me. What else can we do except joke about the insanity?

This past year I faced two formal complaints and government investigations about my address. Both complaints were abandoned following the official investigation. Interestingly, these complaints are not dismissed and no formal proof of exoneration was issued as a result of government investigation is issued. I’ve commented elsewhere that this seems unfair that anyone can make an anonymous complaint about address and have is attached to my professional license record forever. In addition to those two, I have reason to suspect that other investigations, not prosecuted, were conducted by other agencies.

From time to time since the 1990’s I’ve updated a written “Address Policy” and had it reviewed by a personal attorney. This page is the latest effort in that project.  While most people don’t need to be so concerned about address issues, I publish the results of the review here simply to point out that it isn’t always so simple. Also, I have an untested belief that offering transparency in the form of public disclosure may help reduce scrutiny in the future.

History

In the past (and perhaps in the future) I’ve had business licenses in each state and DC. In those states that require an in-state servicing agent, I’ve used the servicing agent’s mailing address. I have a separate home from my family primarily to accommodate my medical issues. We do not believe that the term “legally separated” is meaningful under applicable laws simply because my wife and I have seperate homes, addresses and finances.

Risks

I’ve maintained an active monitoring program of risks that i must avoid:

1. Voting in a location where I’m not eligible.
2. Being registered to vote in more than one location.
3. Not having a license in a state where a license is required.
4. Giving an incorrect address to a government official in error.
5. Facing a challenge in an “in-state” vs. “out-of-state” differential issue.
6. Requirements of the state election commission should I serve as Treasurer of another campaign.

Current Situation

Residence: I previously gifted the family home – my primary residence – in Pennsylvania to my spouse and then moved to New Jersey. She expects to sell that residence in November 2019.  I have been in New Jersey essentially full time since April 16, 2019 and expect to be until October 30, 2019.

Mail: My New Jersey address does not accept mail due (I am told) to US Postal regulations for delivery in a flood zone. The road alongside my yard is often flooded. Alternate arrangements including delivery to a neighbor’s mailbox and a post office box have proved insufficient to some authorities. I now use the PA address as a mailing address for all purposes.

Delivery address: I list the physical address whenever it seems that a personal visit or delivery is required. I am aware that this has caused confusion, but that was not the intention. I do not know why some delivery services, especially UPS, seems to have trouble finding the NJ address on GPS according to one of the delivery men.

Pennsylvania Office: I maintain a physical office in Pennsylvania but do not receive mail there.

Delaware Registered Agent: I do not maintain a physical office or residence in Delaware, but I do maintain a registered agent service address. I notified the Delaware Board of Accountancy of this change.

Driver’s License: My driver’s license renewal used the correct NJ address but the PA mailing address. The printed physical license uses the PA address. That was not by my choice; apparently that’s their system programming. It seems counter-intuitive.

Voter registration: I am registered to vote at the NJ address. This was “automatic” under NJ’s new law at my last license renewal in 2019. Again, this was the default of NJ’s system, not my choice. I have spoken and emailed with the Cumberland County NJ Clerk to confirm this treatment was normal.

CPA licenses: NJ and DE only. AICPA reciprocity rules are used for work in other states. I am currently undergoing a CPA peer review under the regulations of DE. I have notified both DE and NJ of my temporary unstable address situation.

Taxes: In 2018 I filed a joint tax return with my wife using the PA address. In 2019 I expect to file a joint tax return with my wife using here NJ address.

Proposed Changes

I am considering using my wife’s new residence in New Jersey as either a residential address or a mailing address or an office address, or some combination. I have not yet considered the tax, legal and financial consequences of each option.

Review October 23, 2019

While I am aware that some people may have incorrect addresses from the past, I am not aware of any legal deficiency or recommended change at the date of this review.

Attorney review

Incomplete (Note added post-publication: disputes about address quietly resolved in the post-pandemic period so I do not expect that this issue will require professional legal oversight.

Other plans

I will consider the legal, tax, financial, local licensing and state professional licensing requirements before making any other change. Since some of these issues may have timeliness requirements, I expect to complete the review within the next 60-90 days.