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in March 2000. While with e-TECH, petitioner was contracted out
to Hewlett Packard and Johnson & Johnson Medical.
On August 21, 1999, petitioner and Ms. Lynch entered into a
residential tenancy agreement to rent a residence at 5/13 George
Street, Manly. The term of this lease agreement was 6 months,
beginning on September 1, 1999, through March 2, 2000.
On March 2, 2000, petitioner returned to the United States
and stayed at the condominium for 11 days.5 Thereafter, he moved
to an apartment in Denver, Colorado, to work on another
consulting contract.
During 1999 and 2000, petitioner spent approximately 330
consecutive days outside of the United States. Petitioner
returned to Australia in September and October 2000 to perform
additional consulting services for Australian companies.
Petitioner filed Forms 1040, U.S. Individual Income Tax
Return, for each of the years in issue. On each return,
petitioner listed his address as the Syracuse address.
Petitioner attached to each return, inter alia, a Schedule C and
a Schedule E, Supplemental Income and Loss.
On each Schedule C, petitioner identified his business name
as Unix, his principal business or profession as “Admin & Co” for
5 In addition, petitioner stayed at the condominium as
follows: (1) 40 days in 2003; (2) 19 days in 2002; (3) 14 days
in 2001; (4) 69 days in 1998; (5) 18 days in 1997; and (6) during
Christmas in 1996.
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