Richard A. Grigg and Mary G. Grigg v. Commissioner of Internal Revenue

JOHNSON, Circuit Judge:

This- case calls on the Court to construe the hotel exception of section 280A of the U.S. Internal Revenue Code. 1 The district court construed the exception such that the Griggs could not take advantage of it, holding that they were not entitled to claim certain deductions for their South Padre Island Condominium. The Griggs have appealed that decision. We affirm.

I. Facts and Procedural History

In 1983, Richard Grigg and Gary Stephens purchased a condominium unit in The Sunchase Beachfront Condominiums complex located in South Padre Island, a resort area in Texas. In…