- 15 -
ness purposes does not meet the exclusive use requirement of
section 280A(c)(1). Goldberger, Inc. v. Commissioner, supra at
1557. Petitioner has failed to establish that he used any
portion of the motor home solely for the purpose of carrying on
his rental real estate activities. Accordingly, petitioner has
failed to satisfy the exclusive use requirement of section
280A(c)(1). Consequently, 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).9
Based on our review of the entire record before us, we
sustain respondent's determination that petitioner is not en-
titled to deduct for 1989 the motor home expenses at issue.
Meal Expenses
In Schedule E of his 1989 return, petitioner claimed a
deduction of $1,625 for meal expenses. Respondent determined
that petitioner is not entitled to that claimed deduction because
he has failed to establish (1) that those expenses were ordinary
and necessary expenses paid in carrying on a trade or business
under section 162(a) or for the production or collection of
income under section 212 and (2) that he complied with the sub-
stantiation requirements of section 274(d).
9 We note, however, that petitioner also has failed to satisfy
the requirements of sec. 280A(c)(1) because he has not estab-
lished that his rental real estate activities constituted a trade
or business within the meaning of sec. 162(a). See supra notes
4, 8.
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