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condominium and a house, nor used them for personal purposes;
and, although the taxpayers’ children and friends stayed in both
properties, they paid fair market rent to the taxpayers.
In Hambleton v. Commissioner, T.C. Memo. 1982-234, we denied
deductions for expenses relating to farming activities on a 110-
acre tract of farmland because we found that the taxpayers lacked
the requisite profit motive under section 183. We found,
however: “Although * * * [the taxpayers] used approximately one
acre surrounding the house for personal use, * * * [the
taxpayers’] principal motivation in purchasing the 110 acre farm
was to realize a profit through appreciation in the value of the
land.” We denied the deductions only because the taxpayers were
unable to explain how any of the expenses were “ordinary and
necessary to the holding of the property as an investment.” The
taxpayers’ circumstances in Hambleton are readily distinguishable
from petitioners’ circumstances wherein the properties in
question are not obviously divisible into residential and
nonresidential portions and, as far as we can tell, were used
entirely and exclusively as weekend vacation retreats.
Lastly, neither Holmes v. Commissioner, 184 F.3d 536 (6th
Cir. 1999), revg., vacating, and remanding T.C. Memo. 1997-401,
nor Frazier v. Commissioner, T.C. Memo. 1985-61, addresses the
issue of whether a personal residence that the taxpayers use
exclusively for recreational purposes can constitute property
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