- 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.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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