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this were so, there would be no qualified rental period in 1991,
and section 280A(d)(4) would not apply. Petitioner's primary
argument next assumes that section 280A(d)(4)(A) allows his
personal use of the San Bruno residence for the entire year to be
ignored. Unless both assumptions are valid, petitioner's primary
argument must be rejected. Because his second assumption is
invalid, we need not consider the validity of the first.
For purposes of applying section 280A(c)(5), section
280A(d)(4)(A) provides that personal use of a dwelling unit is
ignored for any day during the taxable year that the taxpayer
uses the dwelling unit as a principal residence if that day
occurs before or after a qualified rental period described in
section 280A(d)(4)(B)(i). Any day involving personal use that
occurs during a qualified rental period is not ignored.
According to petitioner, a qualified rental period began on
August 1, 1991, and continued at least through the end of the
year. Even if this were so, section 280A(d)(4) would allow
petitioner's personal use of the San Bruno residence only from
January through July of 1991 to be ignored; it would not allow
his personal use from August through December (during the
qualified rental period) likewise to be ignored. Taking into
account petitioner's personal use of the San Bruno residence
during the qualified rental period would, based solely upon such
use, give rise to the application of section 280A(c)(5). Because
petitioner continued to use the San Bruno residence for personal
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