This falls more in the category of idle speculation than investigation. Further, it makes no business sense to drive a 37 foot recreational vehicle to Hillsboro, Salem or to Lincoln City from Portland. An automobile would be much less expensive and quicker. However, as taxpayer acknowledged, it does make personal sense if taxpayer's wife has severe arthritis and requires a place to stretch out while she is traveling. The court notes that no investments were ever made as a result of these trips.
Taxpayer contends that the rules governing deductions are unfair.
By way of explanation, it is important to remember that the personal income tax system is based on taxpayer-kept records and depends upon the taxpayer assessing his or her own tax. This presents a great temptation for taxpayers to keep records which appear to be business oriented or to characterize nondeductible personal interests as deductible business efforts. To offset this temptation, Congress has chosen a bright-line test requiring office use to be exclusive. This exclusivity requirement overcomes taxpayer rationalizations which may become so extensive as to be deluding. For example, in this case, taxpayer allocated 25 percent to personal use of the motor home.