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purposes (as his residence) while attempting to rent out the
remaining bedrooms, he cannot rely upon section 280A(d)(4) to
avoid the application of section 280A(c)(5). See Walsh v.
Commissioner, T.C. Memo. 1987-18.
Accordingly, we hold that the deductions claimed on the
Schedule E filed with petitioner's 1991 Federal income tax are
limited to the gross income reported on the Schedule E pursuant
to section 280A(c)(5), and respondent's adjustment in this regard
is sustained.
To reflect the foregoing,
Decision will be
entered for respondent.
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