T.C. Memo. 2004-188
UNITED STATES TAX COURT
ROBERT D. AND ANA M. SHIRLEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5003-02. Filed August 24, 2004.
Jan R. Pierce, for petitioners.
Kelley A. Blaine, for respondent.
MEMORANDUM OPINION
HOLMES, Judge: This case is about whether the cost of a
motor home,1 bought to be added to a rental fleet, is deductible.
The contested deduction is not allowable if a motor home is
1 As early as 1920, enterprising Americans began attaching
small homes to Model T chassis to travel the roads in comfort
greater than they could have in a car alone. These improvised
efforts evolved into recreational vehicles, or “motor homes” as
they are called by those in the industry.
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