Staney's job required a lot of travel between Massachussetts, New york and Florida. He bought a membership in a campground that allowed him to place his brand new Airstream on a lot in the campground for long period of time. Electric, water, and sewer were provided by the campground to the Airstream as part of the dues he paid as a member. The rules required Stanley to move the trailer to a different lot within the grounds every 6 months. After years of living this way Stanley decided to buy a house in Pennsylvania and moved in using it as his long term residence. He claimed a first-time homebuyer credit on his federal income taxes. The IRS denied the credit to Stanley since they said his ownership and long term parking of the trailer with utilites was his first home. Stanley claimed it was not home but was personal property so he was entitiled for the tax credit. Was the Airstream personal property ?

Legal reasoning please