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sale of all its assets, and therefore the list is not relevant to
its intention regarding the unit 10 property.
Ridgemark had explored the options available to it with the
intention of disposing of all its assets. Given that Shen had
backed out of an earlier deal, we find it credible that Ridgemark
sought alternatives in the event the transaction might not be
consummated. One of the options was selling to another buyer.
The possession of the names of potential buyers of the unit 10
property, by itself, is not dispositive of this issue.
The existence of a sales office is a weakness in Ridgemark’s
position, but not a fatal one. In this regard, the existence of
a sales office did not result in sales for Ridgemark.
6. The Time and Effort the Taxpayer Habitually Devoted to the
Sales
After the formation of the sister corporations, Construction
and Financial, Ridgemark was substantially involved in the
development and expansion of its golfing and recreational
business.
Ridgemark’s corporate minutes demonstrate that the board of
directors spent significant portions of its time discussing the
proposed transaction with Shen and various aspects of the golfing
business.
There was a symbiotic relationship between the operation of
Ridgemark Golf and Country Club and the sales of land. That
interrelationship generated the dispute concerning Ridgemark’s
trade or business. Although Ridgemark pursued the sale of the
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