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holidays, and possibly for retirement. This is quite obvious
from petitioner's testimony. Petitioners went to Long Beach in
search of a second home, not to invest in a business. The idea
of the nursery was an afterthought. The tail of the nursery
cannot wag the dog of the second home.
Expenses associated with a vacation home are personal and
nondeductible except as otherwise expressly provided in the Code.
Sec. 262(a). Furthermore, section 280A(a) limits the deductions
that may be allowed "with respect to the use of a dwelling unit
which is used by the taxpayer during the taxable year as a
residence." During the years in question, petitioners used, at
least, the cottage on the Oregon Street property as a residence.
It may not necessarily flow from this scenario that the
nursery activity was not entered into for profit. See Hughes v.
Commissioner, T.C. Memo. 1995-202. We have no question that
petitioner may have devoted many arduous hours to the nursery
activity. Based on the record before us, it is virtually
impossible to separate the ordinary and necessary expenses of the
nursery activity from the personal expenses of the second home.
For example, petitioners claimed deductions for utilities and
interest expenses, but we have no evidentiary basis on which to
allocate these expenses between business and personal. It may be
argued that, for example, the car and truck expenses are solely
associated with the nursery activity. But, we simply cannot
accept that there were no personal motivations in the travel to
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