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SHIRLEY v. COMMISSIONER

Docket No. 5003-02.

88 T.C.M. 140 (2004)

T.C. Memo. 2004-188

Robert D. and Ana M. Shirley v. Commissioner.

United States Tax Court.

August 24, 2004.

Attorney(s) appearing for the Case

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 "used predominantly to furnish lodging," but is allowable if a motor home is "used primarily as a means of transportation." It thus asks an imponderable question—when a vehicle can be simultaneously used for both lodging...

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