- 13 - Australia; (2) he kept all his personal belongings in storage in Colorado; (3) he maintained Unix’s “business headquarters” and bank account in Colorado, which indicate his personal desire to return to Colorado; and (4) he lived in the condominium when he returned from Australia. On the other hand, respondent contends that Australia was petitioner’s tax home. We agree with respondent. There is ample evidence in the record to support the conclusion that petitioner’s condominium in Avon, Colorado, did not constitute his primary personal residence. Petitioner lived in the condominium for only 5 days before departing the United States in 1999 and only 11 days after he returned from Australia in 2000. It appears that petitioner resided in the condominium in 1999 for 5 days because it was between the time that he sold the Aurora home, in which he resided for approximately 3 years before departing the United States, and his departure to Australia. In fact, petitioner did not move any of his personal belongings into the condominium, but rather placed them in storage.9 In 2000, petitioner resided in the condominium between the time he returned from Australia and moved into an apartment in Denver, Colorado. Living temporarily in the condominium for 5 9 Petitioner testified at trial that he kept some personal belongings in the condominium. We note, however, that petitioner maintained the condominium as a fully-furnished rental property. As such, petitioner did not move his personal belongings from the Aurora home to the condominium before relocating to Australia.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011