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For the reasons stated, we conclude that no portion of the
expenses of petitioners' residence in Orange, California,
qualifies as deductible expenses of a home office.
Respondent also claims that the mobile unit installed on
the timber farm constituted a personal residence of petitioners
and that for any of the expense of the mobile unit to qualify
for business expense deductions, the mobile unit or some portion
thereof must satisfy the requirements of section 280A. We
disagree.
During the years in issue, the mobile unit was not used as
a personal residence of petitioners. Petitioners’ time on the
timber farm represented all work. No portion thereof is to be
regarded as personal, and the mobile unit is not to be regarded
as a personal residence. See Allen v. Commissioner, 72 T.C. 28,
32 (1979).
Each of petitioners’ trips to and all of petitioners’ time
spent on the timber farm related to the work and business of the
timber farm. Until September of 1989, petitioners lived in
their large personal residence in Orange, California, and
thereafter in their large personal residence in Park City, Utah.
The mobile unit located on the timber farm is not properly
regarded as a personal residence. Petitioners’ use of the
mobile unit was work related and is not to be regarded as
personal.
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