John T. Dorrance (defendant) was born in Pennsylvania.
After his education, he
became employed in New Jersey. There, he was immensely successful as the
head of Campbell Soup Company. Between 1911 and 1925, Dorrance and his
wife lived in a country home in Cinnaminson, New Jersey, with their children. In
November 1925, Dorrance, his wife, and their four children (aged 18, 16, 14, and
10) moved to a much larger, luxurious estate in Pennsylvania known as
Woodcrest. The family lived at Woodcrest, the children went to school there, and
their social lives centered around Woodcrest. Dorrance commuted to work in New
Jersey. Dorrance continuously owned Cinnaminson, where his mother and sister
lived from 1926 until their deaths in 1928 and 1929. Many of Dorrance’s friends
and acquaintances believed he was a Pennsylvania resident after 1925.
Dorrance, however, took measures to claim a New Jersey domicile, such as
executing formal documents to that effect, on account of New Jersey’s favorable
inheritance and estate laws. On his death, the state (plaintiff) sought to establish
that Dorrance was domiciled in Pennsylvania for tax purposes. A trial court
agreed, and the matter was appealed.