Prior to 24th April, 1926, the Respondent was resident and ordinarily resident in the United Kingdom. On that date, he left the United Kingdom to enter the employment of a financial firm in New York. The employment was in the nature of an apprenticeship, with a view to his becoming a European representative of the firm.
During each of the years 1926-27, 1927-28 and 1928-29, lie visited the United Kingdom on his employers' business. He was not a householder in the United Kingdom, nor had he a fixed place of abode there, but he resided at hotels during his visits.
On appeal, the General Commissioners decided that in each of the three years he was not resident in the United Kingdom. Held, that there was evidence on which the Commissioners could come to their finding of fact that the Respondent was not resident in the United Kingdom.