Loren F. Paullus and Donna Paullus - Page 28

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          Country Club, as well as the existing residential developments              
          that Construction and Financial developed and sold.  By itself,             
          property sold as undeveloped land, with development to be done              
          under contract for the purchasers, does not automatically reflect           
          that the land is held for sale to customers in the ordinary                 
          course of a taxpayer’s trade or business.  Reithmeyer v.                    
          Commissioner, 26 T.C. 804, 813 (1956).                                      
               Finally, we note that Ridgemark held the unit 10 property              
          for approximately 4 years prior to the transaction in question.             
          This relatively long holding period also tends to support the               
          conclusion that Ridgemark held the property for investment                  
          purposes.  Ridgemark held a relatively significant amount of real           
          estate from 1977 and 1987 with only limited sales to related                
          companies.  This is more indicative of an investment motive in              
               We note that a sale of a large tract in a single transaction           
          does not necessarily mean that the property was not held for sale           
          in the ordinary course of a taxpayer’s trade or business.  See              
          Major Realty Corp. v. Commissioner, 749 F.2d 1483, 1489 (11th               
          Cir. 1985), affg. in part and revg. in part on another issue T.C.           
          Memo. 1981-361; Williams v. United States, 329 F.2d 430 (5th Cir.           
          1964); Lawrie v. Commissioner, 36 T.C. 1117, 1121 (1961).                   
          However, Ridgemark does not have a history of continuously and              
          regularly purchasing raw land that was later sold for                       

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