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WASHINGTON--Pondering the imponderable: At the U.S. Tax Court, questions often arise that might charitably be defined as arcane. But occasionally they border on the metaphysical. Take, for instance, this one: Is a motor home ``used predominantly to furnish lodging'' or ``used primarily as a means of transportation''?

The question is not without consequence. A deduction taken by a taxpayer would be allowable if a motor home is transportation and not allowable if it is lodging. An Oregon couple, in the business of selling and renting these vehicles, said ``transportation'' and took an accelerated deduction for a motor home they bought and rented out on a short-term basis, calling it business equipment.

The IRS called it ``lodging'' and disallowed the fast write-off. The case, opined Judge Mark V. Holmes, ``asks an imponderable question--when a vehicle can be simultaneously used for both lodging and transportation, how can one tell which is primary?'' His answer: Well, since most of the rentals were for fewer than 30 days, it appeared in this case that the motor home was used more for transportation than lodging.

So the taxpayers could take the accelerated deduction. But as for stating a general principle, the judge said, ``we leave grappling with a difficult element of a difficult test for another case.''And in case you're wondering, there's plenty of precedent for that.

In a footnote, the judge pointed to two other cases, one ``avoiding decision on whether mobile homes were `tangible personal property' '' and the other ``avoiding decision on whether mobile homes qualified as hotel or motel.