-18-
Scheidt v. Commissioner, T.C. Memo. 1992-9 (horse farm and
stallion syndication); Mary v. Commissioner, T.C. Memo. 1989-118
(horse farm and horse racing); Yancy v. Commissioner, T.C. Memo.
1984-431 (same). We conclude that petitioner operated her farm
and Broadmoor Gardens as one activity for purposes of section
183.
Respondent concedes that petitioner prevails on the
Broadmoor Gardens issue if we hold that petitioner operated the
farm and Broadmoor Gardens as one activity. Thus, we hold that
petitioner operated Broadmoor Gardens for profit in 1990 and
1991.
B. Depreciation of the Addition
1. Applicability of Section 280A to the Addition
Section 280A bars business deductions for a taxpayer's
residence, unless an exception applies. Section 280A(c)(1)(A)
allows a taxpayer to deduct home office expenses if the taxpayer
uses the home office exclusively and regularly as the principal
place of any trade or business. Petitioner points out that
visitors to Broadmoor Gardens toured her entire residence and
contends that section 280A does not apply to her residence
because it was her principal place of business, and she used all
of it for business purposes. We disagree. Section 280A applies
to any dwelling unit that is used during the year as a residence,
whether a taxpayer uses part or all of it for business. See sec.
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