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mausoleum crypts, and cremation niches.
Respondent concedes that the Woodbine assets used in the
trade or business not held for sale to customers in the ordinary
course, such as the office building, the residence, the two
service buildings, and the equipment, would qualify for
installment treatment. We also include in the category of assets
qualifying for installment treatment the roads, landscaping, lot
markers, drainage, and fencing.
This leaves to be resolved the characterization of the
Woodbine accounts receivable and undeveloped land.
The unrealized receivables of Woodbine arose from sales of
inventory or property held primarily for sale to customers,
consisting of mausoleum crypts. As such, they were ordinary
income assets, deriving their character from the property that
generated them, property that was held for sale to customers in
the ordinary course of trade or business. See Coast Coil Co. v.
Commissioner, 50 T.C. 528, 532-535 (1968), affd. per curiam 422
F.2d 402 (9th Cir. 1970); Family Record Plan, Inc. v.
Commissioner, 36 T.C. 305, 308-313 (1961), affd. on other grounds
309 F.2d 208 (9th Cir. 1962); Liberty Natl. Bank & Trust v.
Commissioner, T.C. Memo. 1979-74; cf. Fourth Natl. Bank v. United
States, 36 AFTR 2d 75-5226, 75-2 USTC par. 9594 (N.D. Okla.
1975). It would be anomalous to allow the sale of the
receivables to be entitled to installment treatment when the
sales of the mausoleum crypts that generated them were not and
would not have been entitled to installment treatment. Cf.
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