I wouldn't think that it would be so very difficult as long as Steven severs his ties to Minnesota and establishes new ones in SD, or any other state, for that matter. There are many people who own real property in states that they do not live in and sometimes never have.
Steven said his lawyer included language in the contract for deed that would shield him from claims by the state that he retains ownership of the house, to avoid Minnesota using the fact that he still owns the house as an evidence that he is domiciled in Minnesota. But as I said, in any contract for deed the seller
does retain ownership--that's why I'm curious about what the lawyer put in the contract for deed deed to make that not the case in his situation.
But in more general terms, the
Sanchez court put it this way: "Once domicile is established in Minnesota, it is presumed to continue until another domicile is actually established. ... The taxpayer has the burden of proving a new domicile outside of Minnesota." Having a rebuttable presumption may seem to a lot of people like a subtle distinction, or maybe even no distinction at all, but it has significant legal effect.
In the
Sanchez case, they did everything people tell fulltimers to do (get an address in the new state, register to vote, register your vehicles, open a bank account, change your insurance, sell your house in the state you no longer want to be domiciled in). However, the Court said, "There is no evidence that their visits to South Dakota during 2004 were anything more than brief, temporary stays for the purpose of establishing a mailing address." And the Court requires (somewhat torturedly, in my view) that "One must actually reside in the new state at the time the intent is formed to make the new state one's permanent home," and found the Sanchezes didn't do that.
That's why people domiciled in Minnesota who want to not be domiciled there any more need to be really careful about how they go about it because the Sanchezes did everything right (including giving up title to their Minnesota house by selling it, which Steven isn't going to do with a typical contract for deed), and still got tripped up.