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artisans, and similarly-situated individuals (artists). It was
further found that the public will benefit by making such
buildings available for joint living and work quarters for
artists because the new use contributes to the revitalization of
central city areas, the conversion results in building
improvements and rehabilitation, and the cultural life of cities
will be enhanced by the residence of large numbers of persons
regularly engaged in the arts. Moreover, it was found that
artists require larger spaces for the pursuit of their artistic
endeavors and for the storage of materials and products than are
regularly found in dwellings, the financial remunerations to be
obtained from a career in the arts are generally small, artists
generally find it financially difficult to maintain quarters for
their artistic endeavors separate and apart from their places of
residence, high property values and resulting rental costs make
it particularly difficult for artists to obtain the space
required for their work, and the residential use of such space is
accessory to the primary use of such space as a place of work.
As stated, this California Law was relied upon by petitioner to
support her argument that she should be allowed to deduct her
rent expense under section 162(a).
Although we may sympathize with petitioner's argument, such
an argument is not dispositive here. "The proper place for a
consideration of petitioner's complaint is the halls of Congress,
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