Bernard L. Nadeau, Jr. and Nancy L. Nadeau - Page 7

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            speculation and receives rentals therefrom is not a real estate                            
            dealer.  Id.                                                                               
                  Whether property is held by a taxpayer for sale to customers                         
            in the ordinary course of the taxpayer's business or for another                           
            purpose is a question of fact, and each property must be                                   
            considered on an individual basis.  Cottle v. Commissioner, 89                             
            T.C. 467, 486 (1987).  In this analysis, courts have applied                               
            various factors including:  (1) The taxpayer's purpose for                                 
            acquiring the property and the duration of ownership; (2) the                              
            number, frequency, regularity, and substantiality of the sales;                            
            (3) the taxpayer's efforts, including advertising, to sell the                             
            property; (4) the extent of developing and improving of the                                
            property to increase sales; and (5) the taxpayer's time and                                
            effort devoted to sales.  United States v. Winthrop, 417 F.2d                              
            905, 910 (5th Cir. 1969); Cottle v. Commissioner, supra at 487.                            
            These factors serve to guide the decision but none is necessarily                          
            of controlling significance.  Cottle v. Commissioner, supra at                             
            488.                                                                                       
                  Applying these factors, we find that petitioners acquired                            
            and held the Pillsbury and Lyndale properties as investments.                              
            The purpose for acquiring the Eden Prairie property is not clear                           
            from the record; however, petitioner testified that he held it                             
            for investment beginning in 1990.  In contrast, petitioner                                 
            testified that when acquiring the St. Paul property he intended                            
            to resell it immediately after purchase.  However, the existence                           




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