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ties. He allocated approximately 25 percent of those reported
expenses to activities relating to his researching and writing a
novel during 1989 and claimed a deduction of $4,360 in Schedule C
of his 1989 return for the use of the motor home in connection
with those activities. Petitioner allocated the remaining por-
tion of those reported expenses to his personal activities and
did not claim a deduction for the use of the motor home in
connection with those activities.
Meal Expenses
During 1989, petitioner incurred expenses for meals at var-
ious restaurants in the total amount of $6,500. Those expenses
reflected the cost of meals for petitioner and Ms. Perry. During
the year at issue, petitioner did not at any time buy meals for
prospective tenants and did not typically buy meals for then
current tenants. Petitioner allocated 25 percent of the total
meal expenses of $6,500 to his rental real estate activities and
claimed a deduction with respect thereto in the amount of $1,625
in Schedule E of his 1989 return.
OPINION
Petitioner bears the burden of proving that respondent's
determinations are erroneous. Rule 142(a);2 Welch v. Helvering,
290 U.S. 111, 115 (1933). Deductions are strictly a matter of
2 All section references are to the Internal Revenue Code (Code)
in effect for the year at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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