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Section 280A(c) provides certain exceptions to the general
disallowance rule of section 280A(a). The pertinent exception in
the instant case is that prescribed by section 280A(c)(1). That
section provides that section 280A(a) shall not apply to any item
to the extent the taxpayer can establish that such item is
allocable to a portion of his or her dwelling unit that is used
(1) exclusively, (2) on a regular basis, and (3) for one of the
following purposes:
(a) As the principal place of business for any trade or
business of the taxpayer,
(b) as a place of business that is used by patients, cli-
ents, or customers in meeting or dealing with the taxpayer in the
normal course of his or her trade or business, or
(c) in the case of a separate structure which is not at-
tached to the dwelling unit, in connection with the taxpayer's
trade or business.4
Although petitioner's argument is not altogether clear, he
appears to contend that (1) he is entitled to a deduction for
1989 under sections 162(a) and 167(a) for the motor home expenses
reported in Schedule E of his 1989 return because the motor home
was used in connection with his rental real estate activities and
4 In order to satisfy the requirements of sec. 280A(c)(1), the
taxpayer must establish, inter alia, that an expense item is
allocable to a portion of his or her dwelling unit that such
taxpayer used in connection with an activity that constitutes a
trade or business within the meaning of sec. 162(a), and not
merely in connection with an activity that constitutes an income-
producing activity within the meaning of sec. 212. Curphey v.
Commissioner, 73 T.C. 766, 770 (1980).
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