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interest in the New Jersey residence to petitioner; as of the
latter date and until the date it was sold, petitioner was its
sole owner and occupant.
In 1982, petitioner began a regular practice of visiting one
of his sons in Florida during those winter months when it was too
cold for petitioner to work in New Jersey. During these visits,
petitioner stayed at his son’s residence in Daytona Beach,
Florida.
In 1988, petitioner purchased investment property in Daytona
Beach, Florida (the Florida property). The property consists of
two small apartment buildings and two cottages. Petitioner’s son
moved into one of the apartments there (the apartment) and
managed the Florida property for petitioner. The two cottages
and other apartments were rented to third parties. Thereafter,
when petitioner traveled to Florida for the winter months, he
stayed with his son at the apartment.
Sometime during 1991, petitioner decided to work as a truck
driver in Florida during the winter months. In order to do so,
he was required to obtain a Florida commercial driver’s license
and register his truck in that State. In 1992, he did both and
began to work in Florida that winter. Petitioner expected to be
in Florida at the time of the November 1992 presidential election
so earlier that year he registered to vote in Florida.
As it turned out, the income petitioner earned in Florida
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