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Bros. as his evidence of California residence. His July 10,
1996, employment contract, however, guaranteed only 1 week of
work. Explaining his necessity of living in California,
petitioner testified: “In other words, if I lived in New York or
Miami, they wouldn’t want to go to the additional expense to hire
me, because the contracts provide for additional compensation if
you’re working from out of your residence.” He did nothing,
however, that would indicate to other persons, particularly his
creditors and the IRS, that he had moved. To the contrary, the
addresses used by petitioner were all indicative of the residence
in Florida.
Petitioner used Florida addresses on his Federal tax
returns, Forms W-2, and bank accounts. He continued to use a
Florida address on his checks and other banking records and on
his Florida driver’s license at least into 2003. His “loan-out”
corporation, through which he was paid his salary, was a Florida
entity with a Florida address. He did not file California income
tax returns prior to the due date of his 1999 return. We
conclude, therefore, that petitioner resided in Florida at the
time that the liens were filed.
Place of Filing Within Florida
The liens in question in this case were filed with the
Broward County Circuit Court in Fort Lauderdale, Florida.
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