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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.
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