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principal residence (within the meaning of section
1034) of the taxpayer.
(B) Qualified rental period.--For purposes of
subparagraph (A), the term "qualified rental period"
means a consecutive period of --
(i) 12 or more months which begins or ends in such
taxable year, or
(ii) less than 12 months which begins in such
taxable year and at the end of which such dwelling unit
is sold or exchanged, and
for which such unit is rented, or is held for rental,
at a fair rental.
Petitioner considers the San Bruno residence to have been
converted to rental property when he began to advertise the
master bedroom for rent in August 1991. He contends that a
qualified rental period, within the meaning of section
280A(d)(4)(B), began in August 1991 when all of the bedrooms in
the San Bruno residence were either rented or held for rent at
fair rental value. According to petitioner, because a qualified
rental period occurred in 1991, section 280A(d)(4)(A) provides
that his personal use of the San Bruno residence during that year
is ignored for purposes of section 280A(c)(5). If petitioner's
personal use of the San Bruno residence during 1991 were ignored,
it would not be considered to have been used by him during that
year as his residence for purposes of section 280A(c)(5).
Petitioner argues therefore that the rental deductions he claimed
on the Schedule E are not subject to section 280A(c)(5). In the
alternative, petitioner argues that each bedroom in the San Bruno
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