- 4 - during the winter months was sufficient to support him for the entire year. He stopped working in New Jersey and did not file a New Jersey State income tax return for those years that he had no income earned from employment within that State. Petitioner’s 1994, 1995, and 1996 Federal income tax returns were filed listing the apartment as petitioner’s address; the Schedules C, Profit or Loss From Business, included with those returns also listed the apartment as the address of petitioner’s business. Forms 1099 issued to petitioner by third parties for those years were sent to the apartment. From 1992 to 1996, although he no longer worked in New Jersey, petitioner returned to the New Jersey residence in the spring and remained there through the summer and some of the fall seasons each year. During those years he was the only occupant of the house. The utilities always remained in service and the house always remained furnished. With the exception of some clothing and an automobile that he kept in Florida, petitioner kept his personal belongings at the New Jersey residence. Petitioner’s children who lived in New Jersey watched the New Jersey residence when petitioner was in Florida, but none of the children lived there or had keys to it. Petitioner sold the New Jersey residence on July 5, 1996, for $85,000. In connection with the sale, petitioner received $21,000 in cash and a note from the purchasers. The note isPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011