- 32 - 526 F.2d 409 (5th Cir. 1976). Conversely, infrequent sales resulting in large profits tend to show that property was held for investment. Bramblett v. Commissioner, 960 F.2d 526 (5th Cir. 1992). The unit 10 property was sold to Shen for $11,250,000. Previously, Ridgemark was willing to sell the unit 10 property to Shen for $10 million, which incorporated approximately $1,500,000 of offsite improvements, with a $2,563,454 basis. Consequently, at the sale, Ridgemark received net proceeds of approximately $9 million. This is evidence of long-term appreciation as opposed to normal inventory markup. We also recognize that Ridgemark’s golf operating revenue is approximately twice the revenue from real estate transactions. This factor quantitatively reflects that Ridgemark’s primary source of income and business operation was the management of a golf resort facility. The real estate sales were, at best, peripheral. There was a significant difference between the unit 10 property and prior property sales. Ridgemark incurred costs of approximately $2 million in completing the unit 10 property, compared to about $600,000 expended in connection with the seven parcels that had been sold to Financial or Construction. Of the $2 million, approximately $1,600,000 was spent for improvements in satisfaction of the Agreement with Shen. We do not agree with respondent that Ridgemark would have, in any event, made these improvements irrespective of whether Shen completed the sale.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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