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Accordingly, for 1997 petitioners are subject to the limitations
provided in section 280A.
Section 280A(c)(3) provides:
(3) Rental use.–-Subsection (a) shall not apply to
any item which is attributable to the rental of the
dwelling unit or portion thereof (determinated after
the application of subsection (e)).
Section 280A(e) provides:
(1) In general.–-In any case where a taxpayer who
is an individual * * * uses a dwelling unit for per-
sonal purposes on any day during the taxable year
(whether or not he is treated under this section as
using such unit as a residence), the amount deductible
under this chapter with respect to expenses attribut-
able to the rental of the unit (or portion thereof) for
the taxable year shall not exceed an amount which bears
the same relationship to such expenses as the number of
days during each year that the unit (or portion
thereof) is rented at a fair rental bears to the total
number of days during such year that the unit (or
portion thereof) is used.
(2) Exception for deductions otherwise allowable.
-–This subsection shall not apply with respect to
deductions which would be allowable under this chapter
for the taxable year whether or not such unit (or
portion thereof) was rented.
On the instant record, we find that the numerator of the
fraction under the limitation imposed by section 280A(e)(1) is
zero. That is because the numerator of that fraction consists of
the number of days during 1997 that the Doon Way residence was
rented, and we have found that petitioners did not rent the Doon
Way residence during that year. On the record before us, we find
that petitioners have failed to carry their burden of proving
that the expenses that they claimed for 1997 with respect to the
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