Ryan, a resident of Connecticut, is an investment banker in NewYork City and has an apartment in New York City. Cerullo is aresident of New York and owns Cerullo & Company, an accountingfirm incorporated in New York with its principal office inTarrytown, New York. Ryan retains Cerullo to prepare Ryan’sfederal, Connecticut, and New York personal income tax returns. Allmeetings between Ryan and Cerullo take place in New York, Ryancommunicates exclusively with New York tax department personnel,and Cerullo & Company generates a majority of its revenues frompersons residing or doing business in New York. Considering the taxservices Cerullo provides to Ryan,
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