Robert D. and Ana M. Shirley - Page 1

                                 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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