Vacation Home & Mixed-Use Rental: §280A Rules

14-Day / 10% Personal Use Test • Deduction Ordering • Augusta Rule 14-Day Exclusion • 7-Day STR Exception
IRC §280ATreas. Reg. §1.280A-1IRC §469(c)(2)
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A property that is used both personally and rented out falls under IRC §280A, one of the most complex and counterintuitive provisions in the Code. The tax treatment depends entirely on how many days the property is rented and how many days it is used personally. Too many personal use days and you cannot deduct rental losses. Too few rental days and you cannot deduct any rental expenses beyond the rental income. And there is a specific 14-day window - the Augusta Rule - where renting your home produces tax-free income regardless of any other rule.

§280A: The Three Categories

Category 1 - Rented fewer than 15 days: The rental income is completely excluded from gross income. No rental expenses are deductible. The property is treated as a personal residence for all purposes. This is the Augusta Rule - up to 14 rental days per year produce tax-free income with no related deductions.

Category 2 - Rented 15+ days and personal use exceeds the greater of 14 days or 10% of rental days: The property is a "vacation home." Rental deductions are allowed but limited - they cannot exceed rental income (no net rental loss). Deductions are allocated between personal and rental use by days and must be deducted in a specific mandatory order.

Category 3 - Rented 15+ days and personal use does not exceed the greater of 14 days or 10% of rental days: The property is treated as a rental property for tax purposes. Full rental expenses are deductible. Net losses may be passive activity losses (subject to §469 limits) but are not capped at rental income. Standard rental property rules apply.

What Counts as Personal Use

Personal use days are days on which the property is used by: the taxpayer or any co-owner for personal purposes; any member of the taxpayer's family (spouse, siblings, ancestors, lineal descendants) at any rental rate below fair market value; any person under a reciprocal arrangement (you use their cabin, they use yours); or any person at less than fair market rental. Days spent on repairs, maintenance, and renovations do not count as personal use days even if the taxpayer stays at the property while working.

Renting to a family member at below-market rent is a personal use day for the owner. A parent who rents their beach house to their adult child at a discounted rate has personal use days equal to the number of days the child occupies the property. This is the most common trap in vacation home planning - owners assume that any rental is a rental day. It is only a rental day if the property is rented at fair market value to an arm's-length tenant.

The Augusta Rule: 14 Days of Tax-Free Rental

Under §280A(g), if a taxpayer rents their personal residence for fewer than 15 days during the year, the rental income is excluded from gross income entirely. No rental deductions apply - but the income is completely tax-free. The provision is colloquially called the Augusta Rule because Augusta, Georgia residents historically rented their homes during the Masters golf tournament. The rule is straightforward: rent your home for up to 14 days per year at any rate and pay no tax on the income.

The Augusta Rule is occasionally used for business purposes: a business owner rents their home to their own corporation for meetings, retreats, or events. The corporation deducts the rent as a business expense; the homeowner receives tax-free rental income. The rent must be at fair market value for comparable meeting/event space (not inflated), and the meeting must be a genuine business event with documentation. IRS scrutiny of these arrangements has increased.

The 7-Day Short-Term Rental Exception to §280A

A short-term rental property where the average rental period is 7 days or fewer is not subject to §280A at all. Instead, it is treated under the general business activity rules - income is business income and losses are subject to the passive activity rules of §469, but the §280A vacation home limits do not apply. This is why many Airbnb hosts who rent by the night and never use the property personally operate in Category 3 or entirely outside §280A - they either have no personal use days (pure rental) or have average stays of 7 days or fewer (short-term rental exception).

The 7-day average period test is measured by rental, not by property. If your vacation home has ten rental periods during the year and the average length is 6 days (60 total rental days / 10 rentals = 6 days average), the §280A limits do not apply regardless of your personal use. All standard rental deductions apply, and losses are passive activity losses under §469 (potentially deductible against other passive income or against ordinary income if you qualify as a real estate professional).
Authority: IRC §280A (disallowance of certain expenses in connection with business use of home or rental of vacation home - three-category framework; personal use day definition; rental income exclusion for fewer than 15 rental days); IRC §280A(c)(5) (limitation on deductions for vacation home category - deductions cannot exceed rental income; mandatory ordering of deductions: mortgage interest and taxes first, then operating expenses, then depreciation); IRC §280A(d) (personal use day defined - use by taxpayer, family member at less than fair rental value, under reciprocal arrangement, or by any person at less than fair rental value); IRC §280A(g) (rental for less than 15 days - income excluded from gross income; related deductions not allowed; Augusta Rule); IRC §280A(f)(3) (average period of customer use - short-term rental exception; if average rental period 7 days or fewer, §280A vacation home rules do not apply; property treated as rental under §469); IRC §469(c)(2) (rental activities generally passive - except for active participation $25,000 allowance, real estate professionals); Treas. Reg. §1.280A-1 (vacation home regulations - personal use day counting; fair rental value standard; repair day exception); Bolton v. Commissioner, 77 T.C. 104 (1981) (deduction ordering for mixed-use vacation home - IRS method vs. Tax Court method; allocation of mortgage interest and taxes).