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(2) those expenses are not disallowed under section 280A(a)
because his use of the motor home as the principal place of
business for the operations of those activities falls within the
exception provided by 280A(c)(1).5
Respondent contends that petitioner is not entitled for 1989
to a deduction for the motor home expenses at issue because he
failed to prove that the motor home was used in connection with
his rental real estate, rather than personal, activities. Re-
spondent further contends that even if the deductions were other-
wise allowable by the Code, they are disallowed under section
280A(a) because petitioner has failed to establish that he used
the motor home exclusively in connection with his rental real
estate activities as required by section 280A(c)(1).
Petitioner relies on three documents to support his conten-
tion that he used the motor home in connection with his rental
real estate activities and claims that those documents corrobo-
rate his testimony that he used the motor home as a place to meet
with tenants, as a vehicle by which to transport material, as a
storage place to store equipment, and as a vehicle to travel to
various destinations in Oregon in search of new real estate
investments.
Two of the documents on which petitioner relies are the
5 Petitioner concedes that he is not entitled to a deduction for
1989 for the reported motor home expenses that he allocated to
activities relating to his researching and writing a novel during
1989 and for which he claimed a deduction in Schedule C of his
1989 return.
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