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BOLTON v. C.I.R.

No. 82-7013.

694 F.2d 556 (1982)

Dorance D. and Helen A. BOLTON, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided December 2, 1982.

Attorney(s) appearing for the Case

Charles S. Wulke, South Pasadena, Cal., for petitioners-appellees.

Robert Pomerance, Washington, D.C., for respondent-appellant.

Before SNEED and ALARCON, Circuit Judges, and COPPLE, District Judge.

COPPLE, District Judge:

This appeal from the United States Tax Court presents a question involving the interpretation of statutes governing deductibility of expenses incurred in the rental of a vacation home. Dorance and Helen Bolton (taxpayers) owned a vacation home in Palm Springs, California. In 1976, taxpayers rented the unit for 91 days, used it personally for 30 days, and left it unoccupied for 244 days. During that year, taxpayers made interest payments totalling...

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