Stanley M. Kurzet and Anne L. Kurzet - Page 51

                                              - 51 -                                                  
                  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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