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under section 162(a), the taxpayer must establish, inter alia,
that the expense for which a deduction is claimed was incurred
primarily for business, rather than personal, reasons and that
there is a proximate relationship between the expense and the
taxpayer's business. See Henry v. Commissioner, 36 T.C. 879, 884
(1961); Larrabee v. Commissioner, 33 T.C. 838, 841 (1960). The
determination of whether an expenditure satisfies the require-
ments of deductibility under section 162 is a question of fact.
Commissioner v. Heininger, 320 U.S. 467, 475 (1943).
Section 167(a) allows as a depreciation deduction a reasona-
ble allowance for the exhaustion, wear and tear of property used
in a trade or business or for the production of income. No
depreciation deduction is allowed for property that is used
solely for pleasure. Sec. 1.167(a)-2, Income Tax Regs.; see sec.
262.
Section 280A(a) generally disallows a deduction, otherwise
allowable under the Code, with respect to the use of a dwelling
unit, including a "mobile home * * * or similar property", if the
taxpayer's personal use of the unit during the year exceeds the
greater of 14 days or 10 percent of the number of days during
such year for which the unit is rented at a fair rental. Sec.
280A(a), (d)(1), and (f)(1)(A).
3(...continued)
deduction under that section for any of the motor home expenses
at issue. Nor would the record support such an argument, since,
as we hold infra, petitioner has failed to establish that the
motor home was used in connection with his rental real estate,
rather than personal, activities.
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