Issue # 2: How many days did T spend in the U.S. in each year under the carryover days test? Year 3 (2011) Year 3: Current year. As such, must count each day that NRA spent in the U.S. during year 3 as a day full Number of days that NRA spent in the U.S. in year 3: 120 days Number of days under the carryover days test: 120 days x 1 = 120 days Year 2 (2010) Year 2: First preceding year. As such, must count each day that NRA spent in the U.S. during year 2 as 1/3 of a day Number of days that NRA spent in the U.S. in year 2: 150 days Number of days under the carryover days test: 150 days x 1/3 = 50 days Year 1 (2009) Year 1: Second preceding year. As such, must count each day that NRA spent in the U.S. in year 1 as 1/6 of a day Number of days that NRA spent in the U.S. in year 1: 90 days Number of days under the carryover days test: 90 days x 1/6 = 15 days Adding it all up Year 3: 120 days Year 2: 50 days Year 1: 15 days
Issue # 2: How many days did T spend in the U.S. in each year under the carryover days test? Year 3 (2011) Year 3: Current year. As such, must count each day that NRA spent in the U.S. during year 3 as a full day Number of days that NRA spent in the U.S. in year 3: 120 days Number of days under the carryover days test: 120 days x 1 = 120 days Year 2 (2010) Year 2: First preceding year. As such, must count each day that NRA spent in the U.S. during year 2 as 1/3 of a day Number of days that NRA spent in the U.S. in year 2: 150 days Number of days under the carryover days test: 150 days x 1/3 = 50 days Year 1 (2009) Year 1: Second preceding year. As such, must count each day that NRA spent in the U.S. in year 1 as 1/6 of a day Number of days that NRA spent in the U.S. in year 1: 90 days Number of days under the carryover days test: 90 days x 1/6 = 15 days Adding it all up Year 3: 120 days Year 2: 50 days Year 1: 15 days
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