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Being a homemaking guru didn't help Martha Stewart escape a homeowner's tax bill.

New York's Division of Tax Appeals has ordered the new billionaire to pay $221,677 in back taxes for 1991 and 1992.

Stewart, who maintains homes in East Hampton, N.Y., and Westport, Conn., said she did not live in New York for more than half the year in 1992. Those who live in-state for six months owe state income taxes.

"Ms. Stewart has been a resident of Connecticut since 1971 and believes that she was unfairly taxed by the state of New York during the years in question," her publicist, Susan Magrino, said in a statement released Tuesday. "Ms. Stewart and her tax advisers disagree with the decision and intend to appeal."

Administrative Law Judge Thomas Sacca reasoned that Stewart was indeed a New York resident in 1992 and earned taxable income in New York in 1991. His decision was dated Jan. 13.

Stewart is chief executive officer of Martha Stewart Living Omnimedia, a publisher of books and magazines, and producer of a syndicated column and a TV program that gives homemaking and entertaining advice.