Carlton H. Perry - Page 2

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          year (1989 return)?  We hold that he is not.                                
               (2) Is petitioner entitled to deduct for 1989 any of the               
          expenses with respect to meals claimed in Schedule E of his 1989            
          return?  We hold that he is not.                                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Petitioner resided in Portland, Oregon, at the time the                
          petition was filed.  Petitioner and his former wife Barbara J.              
          Perry (Ms. Perry) filed a joint 1989 return.1                               
               During 1989, petitioner spent time researching and writing a           
          novel that had not been published or sold as of the end of that             
          year.  He also held certain investments during that year.                   
               Petitioner's income for 1989, as reported in his 1989                  
          return, included (1) interest income from savings, (2) dividend             
          income from investments in various securities, (3) rental income            
          from investments in rental real estate, and (4) capital gains               
          from the sale of stocks and the sale of rental real estate.                 
          Motor Home Expenses                                                         
               During 1989, petitioner owned a 1987 Pace Arrow motor home             
          (motor home) that was 33 to 34 feet in length and that was                  
          equipped with a kitchen, a bath, a sleeping area, a living area,            
          a television, and a videocassette recorder.                                 


          1  Respondent's notice of deficiency (notice) for 1989 was issued           
          to both petitioner and his former wife Ms. Perry.  Ms. Perry did            
          not file a petition with respect to that notice, and, according-            
          ly, she is not a party in the present case.                                 




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