Robert Lyle Verity - Page 5

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          At all relevant times, petitioner’s business address was 2800 S.            
          Syracuse 8-108, Denver, Colorado (Syracuse address), and                    
          petitioner maintained a business bank account in Colorado.  The             
          nature of petitioner’s work is administering large scale computer           
          systems at the software level, which petitioner generally                   
          performs from a remote location such as his home.  Occasionally,            
          petitioner works on site at various companies setting up the                
          system’s hardware.                                                          
               As part of expanding his business, petitioner desired to               
          develop consulting work with companies in Australia.                        
          Petitioner’s goal was to set up the system hardware and then                
          contract to administer the machine remotely.  To that end,                  
          petitioner became involved with Consultants Exchange AustralAsia            
          (CXC), which is an international contractor management company              
          that matches independent contractors with global companies.                 
          Through CXC, petitioner entered into an employment contract with            
          Getnere Pty Ltd. (Getnere), an outsourcing agency in Australia.             
          Under this contract, Getnere agreed to employ petitioner on a               
          full-time basis not to exceed 6 months duration, beginning on               
          April 27 through October 27, 1999.  Getnere, however, employed              
          petitioner only from April through July 1999.  While with                   
          Getnere, petitioner was contracted out to IBM and Hewlett                   
          Packard.                                                                    







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