Kimberley Rice Kaestner 1992 Family Trust v. N.C. Dep't of Revenue

JACKSON, Justice.

**133In this case we consider whether defendant North Carolina Department of Revenue could tax the income of plaintiff The Kimberly **134Rice Kaestner 1992 Family Trust pursuant to N.C.G.S. § 105-160.2 solely based on the North Carolina residence of the beneficiaries during tax years 2005 through 2008. Because we determine that plaintiff did not have sufficient minimum contacts with the State of North Carolina to satisfy due process requirements of the Fourteenth Amendment to the United States Constitution and Article I, Section 19 of the Constitution of North Carolina, we…