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deductions would be disallowed by section 280A(a). The motor
home owned and used by petitioner during 1989 was a dwelling unit
within the meaning of section 280A(f)(1)(A). See Haberkorn v.
Commissioner, 75 T.C. 259, 260 (1980). In addition, the motor
home was a residence within the meaning of section 280A(d)(1)
because (1) petitioner did not at any time operate the motor home
as a rental property and (2) petitioner concedes that he used the
motor home for personal purposes and does not dispute that his
personal use exceeded 14 days. See sec. 280A(d)(1). According-
ly, assuming arguendo that deductions for the motor home expenses
at issue were allowable under sections 162(a) and 167(a), those
deductions would be disallowed under section 280A(a) unless
petitioner were to establish that they were allocable to a por-
tion of the motor home that was used exclusively and on a regular
basis in connection with his rental real estate activities for
one of the purposes enumerated in section 280A(c)(1).
The exclusive use requirement of section 280A(c)(1) requires
that the taxpayer use a portion of a dwelling unit solely for the
purpose of carrying on a trade or business and that there be no
personal use of that part of the dwelling unit. See Cadwallader
v. Commissioner, 919 F.2d 1273, 1275 (7th Cir. 1990), affg. T.C.
Memo. 1989-356; Goldberger, Inc. v. Commissioner, 88 T.C. 1532,
1557 (1987) (quoting S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3)
49, 186; H. Rept. 94-658 (1975), 1976-3 (Vol. 2) 695, 853)). The
use of a portion of a dwelling unit for both personal and busi-
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