CARSON, C.J.
Taxpayer appeals a decision of the Tax Court, which denied his claim for a refund of taxes paid for tax years 1992, 1993, and 1994. Dept. of Rev. v. Glass, 15 OTR 117 (2000). At issue is whether taxpayer was a resident, under ORS 316.027 (1991), for the tax years in question. We review for errors of law and substantial evidence in the record to support the Tax Court's decision. ORS 305.445.
The Tax Court found the following facts:
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