- 33 - Finally, Ridgemark sold eight parcels of land in a 12-year period between 1977 and 1989. By comparison, only one significant purchase of property was made subsequent to Ridgemark’s 1971 formation (Bushmont property in 1985). Accordingly, Ridgemark fits the pattern of infrequent but substantial sales of property which indicates, generally, that it was held for investment purposes. See Bramblett v. Commissioner, supra. 4. The Extent of Subdividing, Developing, and Advertising To Increase Sales Respondent asserts that Ridgemark routinely subdivided and incurred substantial improvement costs before selling the land to either Construction or Financial. Also, respondent contends that the fact that Ridgemark recorded final subdivision maps on certain property before the sales were complete demonstrates that it was involved in the business of dealing in real property. The seven sales of real property during the 12-year interval between 1977 and 1989 can be divided into two categories: (1) Three sales of large unsubdivided parcels, and (2) four sales in which the title to the property could not be transferred without a new map being recorded to create a separate legal parcel.5 Ridgemark contends that the recordation of a final map 5 See Cal. Govt. Code sec. 66426 (West Supp. 1996), which provides: A tentative and final map shall be required for all subdivisions creating five or more parcels, five or (continued...)Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011