- 29 - 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 propertyPage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 NextLast modified: November 10, 2007