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residence should be considered a separate dwelling unit and
whether and to what extent section 280A applies must be
determined on a bedroom-by-bedroom basis.
Respondent does not agree that the San Bruno residence was
converted to rental property in 1991 or that a qualified rental
period occurred during that year. She suggests that petitioner
did not in good faith attempt to rent out the master bedroom
until he was ready to depart for China in 1992. Consistent with
her position that 1991 did not include a qualified rental period,
respondent argues that section 280(d)(4) does not apply to that
year. According to respondent, because petitioner used the San
Bruno residence as his residence during 1991, section 280A(c)(5)
limits the amount of deductions attributable to its rental use.
In response to petitioner's alternative argument, respondent
argues that the San Bruno residence must be treated as a single
dwelling unit, rather than multiple dwelling units within a
single structure, and section 280A should be applied accordingly.
Because petitioner's alternative argument focuses upon
whether section 280A applies, rather than how it applies, we
consider his alternative argument first. Obviously, the San
Bruno residence is a dwelling unit as that term is used
throughout section 280A. See sec. 280A(f)(1), which defines a
dwelling unit to include a house. Nothing in the statute
prohibits treating a single structure as multiple dwelling units,
and we have done so in appropriate situations. E.g., Gorod v.
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