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managers in the use of the Oracle software system referred to
above. Petitioner terminated his employment with the Fund, and,
sometime in March 1996, he entered into a contract with Josten's
for a period of 6 months commencing on April 1, 1996. Petitioner
began work on or about the scheduled commencement date. By
mutual agreement with Josten's, petitioner worked approximately 1
month beyond the expiration date of the contract, until November
1996. All the work petitioner performed under this contract was
at the business facilities of Josten's at Memphis, Tennessee. He
was not required to travel away from Josten's facilities, and he,
in fact, did not incur any traveling or other expenses in
connection with his contract except those that are at issue in
this proceeding. Moreover, Josten's did not impose on petitioner
any restriction or requirement as to where petitioner was to live
during the contract.
While living in Austin, Texas, petitioner owned a half
interest in a home that he shared with another individual. His
interest in this home was fully paid for, and petitioner retained
that interest while he was engaged on the contract with Josten's
at Memphis, Tennessee. Petitioner did not incur any expenses
relating to the Austin home while he was engaged on the Josten's
contract. Petitioner moved out of the Austin, Texas, home on or
about March 28, 1996, and took up residence with a young lady who
lived at Knoxville, Tennessee, whom petitioner had met in
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